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CU comments on FAQs about Affordable Care Act implementation: Consumer protection principles for reference pricing programs

CU provided comments to the Departments of Treasury, Labor, and Health and Human Services on their FAQs for ACA implmentation.  We focused our comments on a request from the Departments to address whether out-of-pocket maximums should apply to referenced-based pricing programs. CU presented a set of consumer protection principles that should be applied to all reference-based pricing programs.