The U.S. Departments of Labor, Health and Human Services, and the Treasury have finalized regulations under the Affordable Care Act (ACA) that address certain exceptions under the ACA. Among other things, the regulations:

  • Define "essential health benefits" for purposes of identifying plans that are (and are not) subject to the ACA prohibition against annual and lifetime dollar limits;

  • Limit the ACA exception for short-term, limited duration health insurance to arrangements that last no more than three months (and longer arrangements already approved by state insurance regulators to continue up to December 31, 2017); and

  • Address exceptions for supplemental health benefits and for health coverage that is included in certain types of travel insurance.

The new rules generally take effect for plan years beginning on after January 1, 2017.

As the federal health care reform effort gained steam, Ballard Spahr attorneys established the Health Care Reform Initiative to monitor and analyze legislative developments. With federal health care reform now a reality, our attorneys are assisting health care entities and employers in understanding the relevant changes and planning for the future. They also have launched the Health Care Reform Dashboard, an online resource center for news and analysis on developments under the Affordable Care Act.


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