Among the 500-plus pages of health plan guidance issued this week by the Department of Health and Human Services were the latest rules on employer-sponsored health plan out-of-pocket limits.
On page 332 of the document, entitled "Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017," the out-of-pocket limits are set for 2017. The new maximums are $7,150 for individuals and $14,300 for family insurance. Those were the levels recommended earlier by HHS and represent an increase from the current $6,850/$13,700 maximums.
In the document, which includes comments from reviewers and responses to their comments, one comment brought out the differences in calculating out-of-pocket limits by HHS and the IRS.
"One commenter expressed concern over a growing gap between the Affordable Care Act's maximum annual limitation on cost sharing and the Internal Revenue Service's out-of-pocket limit for high deductible health plans (HDHPs) used with health savings accounts. (The 2016 HHS maximum out-of-pocket limitation for other than self-only coverage was $600 above the 2016 IRS out-of-pocket limit on high deductible health plans for other than self-only coverage.) The commenter also expressed concern that the IRS limit is not announced for some months after the HHS limit is known, leading issuers to price products conservatively, and higher than they might otherwise if the IRS limit had been known," the document said.
HHS's response? Essentially, "It's not our problem." Though, the official response was as follows: "HHS and IRS are bound by different statutory parameters when calculating annual out-of-pocket limits. HHS uses the premium adjustment percentage described above to adjust the maximum out-of-pocket limit, and the IRS uses the Consumer Price Index, a measure of inflation, to adjust its out-of-pocket limitation."
A nice way of dodging the two questions posed by the comment.
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