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The more we dig into the requirements employers' group health plans will be facing in 2014 under Health Care Reform, the more little "surprises" we find.  Some of these finds will require plan design changes that employers need to start thinking about now.  One new requirement is the limit on total "cost sharing" that a non-grandfathered group health plan can impose on a participant.  Beginning in 2014, total cost sharing cannot exceed the out-of-pocket limits imposed by Internal Revenue Code Section 223 on high deductible health plans (which are $6,250 for single coverage and $12,500 for non-single coverage in 2013).  What's important here is that "cost sharing" is defined in one section of the Affordable Care Act as including all deductibles, coinsurance, and copayments.  The first round of proposed regulations applies that definition to individual and small group insurance policies, but does not yet provide a definition for large group insurance policies or self-insured group health plans.  If the final regulations use the same definition for self-insured and large insured plans, non-grandfathered group health plans in those categories that do not currently include all of those cost-sharing elements in their out-of-pocket limits will need to be amended before 2014.  A bigger concern for those plans may be the increased costs resulting from implementing this new limit.  Many plans don't include any copayments in the out-of-pocket maximum, or don't include all copayments (like prescription drug copayments).  Plans that don't include copayments in the out-of-pocket maximum might not even be tracking the annual amount of copayments paid by a covered individual.  So compliance with this new requirement may increase both benefit and administrative costs.

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