Healthcare Reform Timeline

 

January 1, 2011

  1. Requirement for medical plan coverage to be available for dependents until they reach age 26.
  2. No lifetime dollar limits on “essential health benefits.”
  3. No revocation of coverage (except for fraud/intentional misrepresentation, non-payment).
  4. No preexisting condition exclusions for enrollees under age 19.
  5. Requirement for coverage of certain preventive health services and immunizations without cost-sharing.
  6. No reimbursement for non-prescribed over-the-counter drugs/ medicines (OTC items) other than insulin, under healthcare Flexible Spending Accounts (FSAs).

 January 1, 2012

  1. Requirement to report the value of each employee’s health coverage on W-2s starting with the 2012 tax year.

September 30, 2012

  1. UA self-funded health plan will be assessed an annual tax of $2 per participant for “comparative effectiveness research.”

 

January 1, 2013

  1. Annual salary reduction contributions to a healthcare FSA may not exceed $2,500.
  2. The current 1.45% individual Medicare payroll tax increases to 2.35% on wages over $200,000 ($250,000 for joint return filers).

 

March 1, 2013

  1. Before March 1, 2013, employers must provide written notice to all employees describing the new Insurance Exchange, explaining the premium tax credit and cost-sharing subsidies (if the employer plan pays less than 60% of costs of benefits) and, if the employer does not offer a free choice voucher, explaining that the employee may lose the employer contribution toward employer-sponsored coverage if he or she elects coverage through the Exchange.

January 1, 2014

  1. Employers must offer “free choice” vouchers to certain eligible employees.
  2. Individuals who do not hold qualifying coverage must pay an excise tax.
  3. Plans must report coverage information to enrollees and the IRS.
  4. State health insurance exchanges begin operating for individuals and small employers.
  5. Eligible employers that offer coverage through an exchange may permit pre-tax contributions through their cafeteria plans.
  6. Waiting periods longer than 90 days prohibited.
  7. Preexisting condition exclusions prohibited for all enrollees.
  8. Plans must cover routine patient costs for care in connection with clinical trials.
  9. Discrimination against providers is prohibited as long as they act within the scope of their licenses.

January 1, 2016

  1.   State health insurance exchanges must be available for employers with up to 100 employees.

 January 1, 2017

  1. States may allow employers of any size to access coverage through health insurance exchange.

 

January 1, 2018

  1.   Excise tax (often called The “Cadillac” Plan tax) applies to high cost coverage.

Automatic Enrollment Requirements

Employers with 200 or more full-time employees become subject to automatic enrollment requirements. Although the statue notes that this provision is to be implemented according to DOL regulations, a specific effective date for this rule was omitted.