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Greetings!
MacCorkle Insurance Service is pleased to provide you with this update - we hope you find the presented topic both interesting and informative. Please look for future editions providing the HR professional with compliance and legislative briefs throughout the year.
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Annual Limits: New ACA Waiver Guidance Provides Relief
On August 19, 2011, the Center for Consumer Information and Insurance Oversight (CCIIO) issued supplemental guidance on stand-alone limited benefit plans which may provide relief for many employers, especially those who are subject to San Francisco's Health Care Security Ordinance (HCSO), originally enacted in 2006. The purpose of this Brief is to discuss the guidance as it applies to employers, generally, as well as to employers subject to the HCSO.
The new guidance automatically exempts stand-alone limited health plans as a class (no application required), from the prohibition of annual benefit limits, so long as the plan meets the following conditions:
- It was established prior to September 23, 2010;
- It reimburses employees for some or all medical expenses (as defined in IRC Section 213(d)), up to a specific dollar limit;
- It allows participants to carry forward unused amounts remaining at the end of the coverage period (e.g. plan year), to the next coverage period for use to pay expenses incurred after the end of the previous coverage period.
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