Smart Benefits: “Embedded” Out-of-Pocket Limits Required for Group Plans in 2016

Rob Calise, GoLocalProv Business/Health Expert

Smart Benefits: “Embedded” Out-of-Pocket Limits Required for Group Plans in 2016

Last week, the Departments of Labor (DOL), Health and Human Services (HHS), and Treasury published FAQs about cost sharing limits to clarify application of the self-only maximums.

Under the ACA, a non-grandfathered group health plan can’t have annual cost sharing that exceeds the maximum annual limitation of $6,600 for self-only coverage and $13,200 for coverage other than self-only for plan or policy years starting in 2015 – limits that increase to $6,850 and $13,700, respectively, in 2016.

Previously, HHS published a Notice of Benefit and Payment Parameters for 2016 stating that annual maximum out-of-pocket limits apply to each individual, whether enrolled in self-only coverage or family coverage. But it raised some questions about its application to self-funded and large group health plans. In response, the FAQs make clear that out-of-pocket limits for single coverage also apply to individuals covered in a family policy in all non-grandfathered plans.

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That means a non-grandfathered group health plan will violate the ACA maximum out-of-pocket limit provision in 2016 unless its limit is no higher than $6,850 for each individual enrolled in family coverage and, in addition, has an overall out-of-pocket limit to the family no higher than $13,700.

Rob Calise is a founding partner of Cornerstone Group, where he helps clients control the costs of employee benefits by focusing on consumer driven strategies and on how to best utilize the tax savings tools the government provides. Rob serves as Chairman of the Board of United Benefit Advisors, and is a board member of the Blue Cross & Blue Shield of RI Broker Advisory Board, United HealthCare of New England Broker Advisory Board and Rhode Island Business Healthcare Advisors Council. He is also a member of the National Association of Health Underwriters (NAHU), American Health Insurance Association (AHIA) and the Employers Council on Flexible Compensation (ECFC), as well as various human resource associations. Rob is a graduate of Bryant University with a BS in Finance.

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