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New Out-Of-Pocket Maximum Rule Is 'Embedded' in HHS Preamble
Benefits Bryan CaveLink to more items from this source
[Guidance Overview]
Mar. 5, 2015

"This embedded rule means that plans (including self-funded plans) will now have to have embedded out-of-pocket limits for each individual covered under family coverage.... The preamble provides that the embedded out-of-pocket limit applies to all plans. Sponsors of high deductible plans (HDHPs) that are intended to be compatible with health savings accounts (HSAs) should note that the out-of-pocket limits set by the IRS for HSA compatible HDHPs are lower than the limits set by HHS for Affordable Care Act purposes.... It is not entirely clear whether the clarification applies for 2015 plan years, which are now underway, or to 2016 and later plan years."

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