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CMS Issues New Guidance for Mini-Med Waivers

On June 17, 2011, the Center for Medicare and Medicaid Services' (CMS) Center for Consumer Information and Insurance Oversight (CCIIO) set a deadline of September 22, 2011, for sponsors of mini-med plans to apply for waivers of the rule against annual dollar limits on essential health benefits. CMS also set the same September 22 deadline for mini-med plan sponsors to apply for an extension of current waivers of the rule against annual limits.

For sponsors of mini-med plans with current annual limit waivers for plan and policy years beginning before January 1, 2014, CCIIO will extend the duration of those waivers through 2013 if:

  • Applicants submit annual information about their plan;
  • Applicants comply with requirements to ensure that their enrollees understand the limits of their coverage; and
  • Existing waiver recipients apply to extend their current waiver by September 22, 2011.

After September 22, 2011, CCIIO will no longer consider applications for an extension. In addition, CCIIO announced that any mini-med plans that have not yet applied for an annual limits waiver must apply by September 22, 2011.

The CCIIO guidance is available at:

The CMS press release is available at:

A fact sheet on annual limits is available at: