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Compliance Q&A: High Cost Claimants: ACA, ADA and HIPAA Considerations

Summary

It’s no secret that high cost claimants can severely impact a group health plan’s bottom line. Creative companies are increasingly developing strategies to limit the impact of these individuals, particularly in the context of self-funded plans. However, there are important limitations on plan sponsors’ ability to engage in strategies to limit or remove coverage of high cost claims. These include compliance with the Americans with Disabilities Act (ADA), the Health Insurance Portability and Accountability Act (HIPAA), and the Affordable Care Act’s (ACA’s) prohibition against employer payment plans.

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