"The final policy may impact health plans that are not directly required to provide EHB, such as self-insured group health plans and large-group market fully insured plans that must follow the annual and lifetime dollar-limit restrictions on EHB and annual cost-sharing limitation requirements.... The final policy is consistent with CMS' desire to provide the 'regulatory framework' for innovation, without mandating it.... Issuers should plan to follow the timelines as outlined by their State and CMS. This policy is subject to litigation in Columbus II. "  MORE >>