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Regarding lifetime dollar limits, are stand-alone retiree plans subject to the ban on these limits?

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Regarding lifetime dollar limits, are stand-alone retiree plans subject to the ban on these limits?

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Until regulations are issued, it is unclear whether the ban on lifetime limits will apply to stand-alone retiree plans. Retiree-only plans hoped to be able to continue to rely on an exemption under HIPAA for plans with less than two participants who are current employees as the basis for concluding that they are not subject to HIPAA’s mandates. But that has been called into question following PPACA. We expect guidance on this issue. We know the IRS will no longer consider over-the-counter (OTC) medications without a “prescription” as qualified medical expenses that can be paid out of health accounts (FSAs, HRAs, HSAs) beginning on January 1, 2011. Have there been any other changes to health accounts or what the IRS considers qualified medical expenses? The law has not changed the allowable qualified medical expenses people can pay using FSAs, HRAs, and HSAs other than excluding OTC medications without prescriptions. People can continue to pay for all other qualified medical expenses th

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