Small group maximum deductible limitations repealed

April 3, 2014

Recall that on March 5, the Department of Health and Human Services (HHS) finalized the maximum deductible limitations for 2015. Maximum deductible limitations were only applicable to small groups.

For 2015, the final maximum deductible limitations were set at $2,050 for self-only coverage and $4,100 for coverage other than self-only.

On March 31, the small group maximum deductible limits established by the Affordable Care Act were repealed when the United States Senate passed H.R. 4302 (known as the “Protecting Access to Medicare Act”).

The legislation includes a number of extenders and other policies, including repeal of the small group maximum deductible limits stated above. This legislation provides a 12-month delay in the Medicare Sustainable Growth Rate (SGR) formula, preventing a 24 percent decrease in Medicare physician reimbursement otherwise set to go into effect April 1. Other key provisions include a one-year delay in ICD-10 implementation, a one-year extension of Medicare Special Needs Plans (SNPs) and a one-year delay in the Medicaid disproportionate hospital (DSH) reductions.

H.R. 4302 was passed in the U.S. House of Representatives on March 26. The bill will be signed into law shortly by President Obama and the effective date would be retroactive to the passage date of the Patient Protection and Affordable Care Act (March 23, 2010).

At this time, the removal of these maximum deductible limits does not affect the other cost sharing limits that have been established (such as the 2015 out-of-pocket maximum limits of $6,600 for self-only coverage and $13,200 for coverage other than self-only) or the actuarial value requirements for 2015 benefits.

Where can I find more information?

More information can be found here.

The information in this document is based on preliminary review of the national health care reform legislation and is not intended to impart legal advice. The federal government continues to issue guidance on how the provisions of national health reform should be interpreted and applied. The impact of these reforms on individual situations may vary. This overview is intended as an educational tool only and does not replace a more rigorous review of the law’s applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. As required by US Treasury Regulations, we also inform you that any tax information contained in this communication is not intended to be used and cannot be used by any taxpayer to avoid penalties under the Internal Revenue Code.