Out-of-Pocket Rules

HR Policy Association is concerned that guidance from the Departments of Labor, Treasury, and Health and Human Services on the maximum annual cost sharing limitations for large group and self-insured employers. The Departments’ guidance, which creates an "embedded" individual out-of-pocket limit in family health care plans, is fundamentally at odds with the Affordable Care Act, the Public Health Service Act, and the Internal Revenue Service Code, as well as the regulatory text implementing those statutes. The guidance on out-of-pocket limits policy will have a significant impact on the cost of providing health care benefits and add to the complex administrative and financial challenges imposed by the Affordable Care Act. The Association believes the Departments should withdraw the guidance.