Recent HHS guidance interprets the ACA’s cost-sharing mandate as requiring certain health plans with family coverage to "embed" an out-of-pocket limit for each covered individual. The limit can't exceed the annual statutory cap on self-only coverage ($6,850 in 2016). This is typically the opposite of how most HSA plans function today. Of course, for lower-deductible HSA-compatible plans, you are basically forced to have a non-embedded deductible to stay HSA-eligible, and most plan administrators have matched up the methodology of the deductible with the methodology for the out-of-pocket maximum — either both embedded or both non-embedded. A number of years ago, one administrator even indicated that their system “forced” these to be matching. Questions remain about the applicability of this guidance to nongrandfathered self-insured and large insured group health plans, but if it does apply, it will likely mean most HSA plans will be getting richer for the participant — in other words, have a higher actuarial value — unless other changes are also made.
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