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Affordable Care Act FAQs: Cost-Sharing Limitations and Provider Non-Discrimination

The DOL recently released a new set of Frequently Asked Questions (“FAQs“) related to the implementation of the Affordable Care Act (the “ACA“). In these FAQs, the DOL clarified that (1) the self-only annual limitation on cost sharing applies to each individual covered under family coverage and (2) this embedded deductible must be applied beginning with the 2016 plan year. ?├íThe FAQs also state that the ACA’s prohibition of discrimination against health care providers who are acting within the scope of their license or certification will not be enforced against a group health plan or health insurance issuer so long as the plan or issuer is applying a good faith, reasonable interpretation of the ACA’s nondiscrimination requirement.

The FAQs are available here.

The lawyers of our Employee Benefits and Executive Compensation Practice Group are readily able to assist companies on a nationwide basis with implementing sophisticated benefit plans and providing answers to their most challenging compensation issues. Additionally, our lawyers are well aware of the daily employee benefits challenges facing companies of all sizes and are capable of helping in-house lawyers and human resources personnel with the day-to-day advice and guidance necessary to properly administer employee benefits plans.

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