New HHS Regs 'Clarify' That Health Plans Covering Families Must Have 'Embedded' Individual Cost-Sharing Limits

"[HHS] now requires group health plans to embed an individual cost sharing limit within the family limit.... The HHS clarification is not effective until plan years beginning on or after January 1, 2016. It is important to note that, at the moment, it is unclear whether the HHS clarification is intended to apply to self-insured plans.... Additionally, all previous cost sharing guidance applicable to self-insured plans have been issued jointly by the HHS, Department of Treasury and [DOL]. As of the date of this [article], the Departments of Treasury and Labor have not issued a similar clarification."