A client of mine has health coverage that doesn't limit or exclude auto accident injuries but has more than one deductible, including one or more higher than $6,000. Is it Qualified Health Coverage (QHC)?

Per the clear language of the statute, “any annual deductible” that is $6,000 or less per individual (i.e., an individual deductible) means that the coverage is QHC. This includes any type of individual deductible, whether it is in-network or out-of-network. It also includes deductibles that are offset in any manner (e.g., by funds contributed to health reimbursement accounts). If any individual deductible is $6,000 or less and does not limit or exclude coverage for auto accident injuries, that coverage is QHC. Please see Bulletin 2020-33-INS for more information.