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| Reminder: Non-Grandfathered Plans Must Implement Embedded Out-of-Pocket Maximums Proskauer's ERISA Practice Center  [Guidance Overview] July 14, 2015 "[A]s employers plan for 2016 open enrollment, they must ensure that their benefit structures are consistent with this new rule. This includes updating their summary plan descriptions and contacting their vendors to ensure that the administration is consistent with this rule. Particular attention must be paid to non-grandfathered high deductible health plans (HDHPs), to which this new rule also applies. High deductible plans often have no embedded limit, applying the family out-of-pocket maximum to all family members in the case of family coverage." |
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