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ERISA Industry Committee Comment Letter to DOL, HHS and IRS on ACA Out-of-Pocket Rules (FAQs Part XII) (PDF)
The ERISA Industry Committee [ERIC]
[Opinion] Apr. 25, 2013
"The out-of-pocket limits should apply only to essential health benefits, as determined in good faith by large employers. The out-of-pocket limits should apply only to the employer's lowest cost coverage that provides minimum value ... The Departments should affirm that the out-of-pocket limits do not apply to retiree health plans.... The limitation on the amount for deductibles should apply only to health plans in the small group market."
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