The agencies have jointly issued an FAQ that sets the \u00a71302(c) out-of-pocket limits for 2016. Those limits will be $6,850 for single-only coverage and $13,700 for family coverage. The 2015 limits are of course $6,600\/$13,200 respectively. More noteworthy in this announcement is that beginning in 2016 for all non-grandfathered plans \u2013 insured and self-insured \u2013 HHS confirms an earlier and somewhat controversial position that the self-only out-of-pocket limit should apply to each individual regardless of whether that person is enrolled in self-only coverage or family coverage.<\/p>\n
The announcement offers this example of how the out-of-pockets will be applied in 2016 and thereafter. A plan has maximum family out-of -pocket of $13,000. The following claims have accrued within an enrolled family unit:<\/p>\n
First, the single-only \u00a71302(c) limit of $6,850 applies to each person irrespective of family enrollment. Since \u201cA\u201d had $10,000 in claims, he\/she would come out of pocket for $6,850 and the plan is responsible for the balance – $3,150. Now, the other three family members – with $3,000 each – are out of pocket those amounts since none of them have reached the individual $6,850 ceiling; but the plan\u2019s<\/i> family aggregate now comes into play. The family has come out of pocket for $15,850 \u2013 the sum of each member\u2019s out-of-pocket — $6,850 + $3,000+$3,000+$3,000. Since the plan\u2019s family aggregate is $13,000, the plan will have to cover another $2,850 ($15,800 – $13,000).<\/p>\n
JSL Comment: \u00a0The agencies\u2019 interpretation of health care reform\u2019s annual cost-sharing limitation effectively embeds an individual out-of-pocket limit in all family group health plans with a higher family deductible\u2014whether or not the high-deductible coverage is meant to make employees HSA-eligible. While this methodology does not take effect until 2016, self-funded plans and insurers will have to begin work now in order to re-tool systems to adjudicate claims under this protocol.\u00a0<\/em><\/p>\n <\/p>\n Not everyone is an expert on health care reform. But the folks at\u00a0J. Smith Lanier<\/a>, one of our endorsed services providers, are.\u00a0 For this reason they created a publication called the\u00a0Health Care Reform Alert. J. Smith Lanier has been providing these to its clients since 2010 when the bill was passed and now offers it to the members of ABA.\u00a0It is J. Smith Lanier\u2019s intention in the alerts to take the many pages generated\u00a0by the Centers for Medicare and Medicaid Services, U.S. Department of Labor or Treasury and filter them down into terms that all can understand. For more information on how J. Smith Lanier can help your bank, contact\u00a0Tom Younger<\/a>\u00a0at\u00a0(256) 890-9027.<\/em><\/p>\n","protected":false},"excerpt":{"rendered":" The agencies have jointly issued an FAQ that sets the \u00a71302(c) out-of-pocket limits for 2016. Those limits will be $6,850 for single-only coverage and $13,700 for family coverage. The 2015 limits are of course $6,600\/$13,200 respectively. More noteworthy in this announcement is that beginning in 2016 for all non-grandfathered plans \u2013 insured and self-insured \u2013 HHS confirms an earlier and somewhat controversial position that the self-only out-of-pocket limit should apply to each individual regardless of whether that person is enrolled in self-only coverage or family coverage. The announcement offers this example of how the out-of-pockets will be applied in 2016 […]<\/p>\n","protected":false},"author":1,"featured_media":475,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","default_image_id":0,"font":"","enabled":false},"version":2},"jetpack_post_was_ever_published":false},"categories":[27],"tags":[],"class_list":["post-665","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-health-care-alert","has_thumb"],"jetpack_publicize_connections":[],"jetpack_featured_media_url":"https:\/\/i0.wp.com\/albanknews.com\/wp-content\/uploads\/2014\/11\/HCA.png?fit=500%2C500&ssl=1","jetpack_shortlink":"https:\/\/wp.me\/p4Y3P2-aJ","jetpack_sharing_enabled":true,"jetpack-related-posts":[],"_links":{"self":[{"href":"https:\/\/albanknews.com\/index.php?rest_route=\/wp\/v2\/posts\/665","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/albanknews.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/albanknews.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/albanknews.com\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/albanknews.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=665"}],"version-history":[{"count":3,"href":"https:\/\/albanknews.com\/index.php?rest_route=\/wp\/v2\/posts\/665\/revisions"}],"predecessor-version":[{"id":668,"href":"https:\/\/albanknews.com\/index.php?rest_route=\/wp\/v2\/posts\/665\/revisions\/668"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/albanknews.com\/index.php?rest_route=\/wp\/v2\/media\/475"}],"wp:attachment":[{"href":"https:\/\/albanknews.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=665"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/albanknews.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=665"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/albanknews.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=665"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
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