For plan years beginning Sept. 23, 2011, unless the U.S. Department of Health and Human Services grants a waiver, group health plans that impose annual or lifetime limits on the dollar value of essential benefits are restricted to imposing an annual limit of $1.25 million.
Break: For plan years beginning before 2014, when waivers will no longer be available, stand-alone health reimbursement accounts (HRAs), which were in effect prior to Sept. 23, 2010, have received a blanket exemption from the annual waiver application process.
Warning: HRAs must still comply with the record retention requirement and annually notify employees that they can continue to impose limits on essential benefits. Model language is available at http://tinyurl.com/6y79qmg.
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