Are self-funded plans still subject to the same out-of-pocket limits as fully-insured plans?

Yes. The ACA’s out-of-pocket limit applies to all plans that provide minimum essential coverage (and all group health plans provide minimum essential coverage, even if they do not provide minimum value).

From CMS: PHS Act section 2707(b), as added by the Affordable Care Act, provides that a non-grandfathered group health plan shall ensure that any annual cost-sharing imposed under the plan does not exceed the limitations provided for under sections 1302(c)(1) and (c)(2) of the Affordable Care Act. Section 1302(c)(1) limits out-of-pocket costs .

Here’s the link:

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