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ACA Rules for Embedded Individual Out-of-Pocket-Maximums to Apply in 2016
Towers WatsonLink to more items from this source
[Guidance Overview]
June 23, 2015

"Group health plan sponsors will need to appropriately credit incurred eligible health expenses toward the plan's [out-of-pocket maximum (OOPM)]. They must also consider whether to separate EHBs from non-EHBs or use one in-network OOPM for all health benefits. To apply the embedded OOPM only to in-network EHBs, the plan sponsor must clearly define which expenses will be considered EHBs for purposes of the plan.... [M]any employer-sponsored group health plans are expected to apply the OOPM to both in-network EHBs and non-EHBs to avoid the administrative burden of separating them out."

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