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  • Home Employers Industry Insights Informed on Reform Embedded Out-of-Pocket Maximum

    Embedded OOP Customer Impacts

    Since 2016, most health plans cannot allow any individual, including those with family coverage, to spend more than the individual out-of-pocket (OOP) maximum expense established under the Affordable Care Act (ACA). Commonly referred to as an embedded individual OOP maximum, this rule could impact a family’s total health care expenses, especially if only one family member incurs high medical expenses.

    How it works

    Once an individual with family coverage meets the individual OOP maximum, the plan must pay 100% of all covered expenses for that person, even if the family maximum has not been met.

    Once the family OOP maximum is reached the plan must pay 100% of all covered expenses for every covered individual — regardless of whether each family member has reached the individual maximum.

    Considerations for Health Savings Account (HSA) plans

    HSA-compatible high-deductible health plans (HDHPs) need to follow additional Internal Revenue Service (IRS) rules for OOP maximums. Those rules:

    • Require deductible thresholds to be met before a plan begins to pay coinsurance
      • Thresholds are set for 1) self-only coverage for individuals, and 2) family coverage for an entire family, including any covered individuals
    • Allow a separate individual deductible that is at least as high as the minimum family deductible threshold

    More information

    Learn more about cost-sharing limits.

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