The Patient Protection and Affordable Care Act of 2010 and the Health Care and Education Reconciliation Act of 2010 (collectively, the “Act”) create a broad roster of new requirements and prohibitions affecting individual and group health insurance contracts and employer-sponsored group health plans. These include curbs on lifetime and annual limits, coverage of preventative care, and limitations on waiting periods, among many others. On June 22, 2010, the Internal Revenue Service, U.S. Department of Labor, and U.S. Department of Health and Human Services issued an interim final regulatio (the “Regulation”) interpreting the following provisions of the Act...