We previously posted a summary of the “clarification” under the Affordable Care Act to the effect that an individual out-of-pocket maximum (“OPM”) may need to be embedded in family coverage. A new FAQ describes how this embedded individual OPM works with a high deductible health plan (“HDHP”). A HDHP that has, for example, a $10,000 family deductible may provide payment for covered medical expenses for a covered person (without violating statutory requirements applicable to HDHPs) if that covered person has incurred covered medical expenses during the year of at least $2,600 (the minimum deductible for a 2015 family HDHP). The HDHP must also apply the individual OPM limit ($6,600 in 2015) to each covered person in the HDHP, even if this amount is below the plan’s $10,000 family deductible limit.
The FAQ can be found here.