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The Scoop on MOOP
McGuireWoods Link to more items from this source
[Guidance Overview]
Aug. 20, 2015

"[FAQ XXVII] stated, 'the self-only maximum annual limitation on cost sharing applies to an individual who is enrolled in family coverage or other coverage that is not self-only coverage under a group health plan.' The FAQ also stated that the departments would apply the clarification only for plan or policy years beginning in or after 2016.... The chairmen [of the House Ways and Means, Education and the Workforce and Energy and Commerce committees] have asked [HHS to provide] ... [1] the source of the statutory authority to enable the Administration to make this change in the [maximum out-of-pocket (MOOP)] limits; [2] any analyses that the Administration has conducted on the impact of the change on employers and employees; and [3] an explanation of the basis for HHS's justification for making the policy change in a preamble and not in regulations."

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