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If I am wrong you should be able to prove me wrong. The pdf is very clear. Its a Gap Plan. It is not a Qualified Health Insurance Policy.... it is not MEC... it says that on the cover of the pdf for the product.Wrong on both counts.
That is not necessarily a bad thing. But its a fact. That plan is not MEC or a Qualified Health Policy under ACA.
And having caps on benefits makes it a Gap Plan by definition.