ACA Annual Limits Rule and ABA Caps
The federal rule helps explain why the statute’s annual maximums are not applied.
What the rule says
The prohibition
Group health plans and issuers may not set lifetime limits, and generally may not set annual limits, effective for plan years beginning after January 1, 2014.
Non-essential benefits
Annual or lifetime limits on benefits that are not essential may be placed as permitted by federal or state law.
Connection to ABA
If ABA is an essential health benefit, an annual dollar cap would fall within the prohibition.
Our reading
This explains the regulator’s stricter message, but it is our reading and not the state’s statement.
Back to the ABA guide.
ACA Annual Limits Rule and ABA Caps: short answers
Does it apply to self-funded plans?
It applies to group health plans, but a self-funded plan is not required to cover ABA at all.
Does it bar visit limits?
It addresses dollar limits, not visit limits, which the state statute bars separately.
Who should confirm?
Your counsel.
ACA Annual Limits Rule and ABA Caps: not legal advice. Send us your renewal.
Where these details come from
The laws and rules named on this page link to the official text. This is general information, not legal advice, and rules change, so check the current text.
42 U.S.C. 300gg-11 (no lifetime or annual limits)
42 U.S.C. 18022 (essential health benefits)
Michigan House Fiscal Agency: Autism Spectrum Disorder fiscal forum
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