When are annual and lifetime limits allowed?

Recent regulations confirm that the general prohibition on annual and lifetime limits applies only to “essential health benefits.” That is, annual and lifetime limits are permissible for “non-essential” health benefits.

In addition, for plan years beginning before January 1, 2014, group health plans may establish annual limits on the total dollar value of essential health benefits for any individual, so long as those limits are not below the following dollar amounts:

  • $750,000 for plan years beginning on or after September 23, 2010 but before September 23, 2011;
  • $1.25 million for plan years beginning on or after September 23, 2011 but before September 23, 2012; and
  • $2 million for plan years beginning on or after September 23, 2012 but before January 1, 2014.

The regulations do not currently prohibit day or visit limits, so unless further guidance is issued to the contrary, such limits seem to be permissible.

For more information, please see our alert Health Care Reform: Navigating Annual and Lifetime Benefits.

Today’s post was contributed by Maureen Maly and Jessica Faith.

Comments

  1. Mike Masters says:

    In designing the benefits for a self-funded plan….can anyone tell me EXACTLY what the minimum esential benefits can look like? How minimum can minimum be?

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