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Changing a Plan Year Won't Work to Extend the Plan's Eligibility for Application of Previously Granted Waiver of Rule Prohibiting Annual or Lifetime Caps
Solutions Law Press [Guidance Overview] Apr. 29, 2013 "[With respect to a previously granted waiver of the ACA's rule eliminating annual or lifetime income caps for certain non-grandfathered plans that applied for same, the federal agencies stated, in the recently issued "FAQ XV," that] changes in plan or policy years made after the waiver is obtained and while a waiver remains in effect do not change the termination date of an otherwise applicable waiver. Rather, Annual Limit Rule waivers are granted based on the date of the plan or policy year in effect when the initial application was submitted regardless of whether the plan or issuer later amends its plan or policy year." |
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