"Under recent guidance from [HHS], a plan must apply the annual limitation on cost sharing for self-only coverage to OOP maximums for each individual in a family plan -- even if this amount is below the family OOP maximum. HHS initially posted an FAQ stating that this requirement applies similarly to deductibles for each individual in the plan, even if this amount is below the family deductible; however, HHS later removed that FAQ from its website without explanation. Thus, although it is not clear, a plan that applies a family deductible that exceeds the ACA self-only OOP limit (of $6,850 for 2016) may need to apply an embedded self-only deductible not exceeding that amount."

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