ACA Deductible Limits Repealed for Small Group Market

On April 1, 2014, President Obama signed the "Protecting Access to Medicare Act of 2014" into law. The new law mainly focuses on Medicare reimbursement rates for doctors. A small, easily-overlooked provision of the law retroactively eliminates the Affordable Care Act's (ACA) annual deductible limit for health plans in the small group market.

The ACA's annual deductible limit was effective for plan years beginning on or after Jan. 1, 2014, but many small employer plans were not required to comply with the limit due to an actuarial value exception created by the Department of Health and Human Services (HHS). The repeal of the ACA's deductible limit is retroactively effective to the date of the ACA's enactment in March 2010. Due to the repeal, small employers will have more flexibility to select health plans with higher deductibles. The new law does not affect the ACA's out-of-pocket maximum, which applies to all non-grandfathered health plans for plan years beginning on or after Jan. 1, 2014.