In late February, the departments of Health and Human Services, Labor and Treasury released final rules clarifying how self-insured plans are to comply with ACA’s cost sharing limitations and how they must calculate minimum value.
The final rule confirms that the amounts paid for deductibles, co-pays and co-insurance cannot exceed the maximum out-of-pocket limits for a high-deductible health plan defined under HSA rules for 2014.
The rule also confirmed that self-funded plans are not required to comply with the annual deductible limits that apply to fully-insured health plans for small groups, which are $2,000 for single coverage and $4,000 for family coverage.
Determining Minimum Value
The final rules also establish that self-funded plans will meet the Minimum Plan Value threshold if the employer’s share is at least 60 percent of the total. An employer’s contributions to an HSA and new amounts made available under an “integrated” HRA will be taken into account in determining the employer’s share of the total.
More specifically, here are a few ways Minimum Plan Value can be determined:
- The Minimum Plan Value calculator made available by the Department of Health and Human Services and the IRS can be used
- Any safe harbor established by HHS and the IRS can be used
- Plans that are not suitable for either the above methods due to non-standard features, can use an actuary to certify Minimum Plan Value
Clients with specific questions on these final rules may contact our compliance specialists at any time.
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In cooperation with NAEBA