VT| Vermont DFR Insurance Bulletin #171 (revised December 10, 2025) clarifies that 8 V.S.A. § 4092 establishes an out-of-pocket maximum on prescription drug costs for any insurance or other health benefit plan offered by a health insurer or PBM, benchmarked to the federal statutory annual minimum deductible for HSA-qualified HDHPs under Internal Revenue Code § 223; while the bulletin answers FAQs on scope, counting of expenses, and HDHP coordination, it does not change prior substantive requirements and emphasizes that plan design and HSA tax issues remain governed by the Internal Revenue Code and IRS guidance.