May carriers continue to impose benefit-specific annual dollar limits on essential benefits?
We believe that PPACA addresses only overall annual limits rather than benefit-specific annual dollar limits. Failure to permit carriers to continue to impose benefit-specific annual limits for essential benefits such as medical equipment and medical supplies may result in more harm to the health insurance market prior to the major market reforms in 2014. Requiring carries to discontinue this common practice may compel discontinuation of certain essential benefits prior to 2014 or the imposition of premium increases that make coverage cost prohibitive. The exception to benefit-specific annual limits would be for preventive services. The PPACA requirement for coverage of preventive care is very specific. Included in that requirement is a list of services, all of which must be provided. Any cap that would preclude an enrollee from receiving all the required services or compel an enrollee to choose between preventive services would be contrary to PPACA. Caps on preventive services must be
