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Question:

An employer offers a high-deductible health plan that starts on October 1 every year. What approach should the plan take regarding the legal requirements related to the annual minimum deductible and out-of-pocket maximums, which are based on a calendar year?

• The plan should apply those limits that are currently in effect on the first day of the plan year (October 1) and not change them on January 1.
• The plan should apply those limits that are currently in effect on October 1 and then change them on January 1 when the new limits take effect.
• The plan should apply the new limits for the upcoming calendar year as of October 1.
• The plan should blend the limits for the two calendar years on a proportional basis.