Employee Benefits Compliance, HCR Timelines, Timeline

Health Care Reform Time Line

2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2018

2010

  • Restricted annual dollar limits on Essential Health Benefits
  • Elimination of lifetime  dollar limits on Essential Health Benefits
  • Dependent coverage for young adults up to age 26
  • Grandfather status for some plans
  • New rescission rules
  • Changes to appeals process and external review requirements
  • No pre-existing conditions limits for enrollees under age 19
  • First-dollar coverage of preventive care
  • Small business tax credits
  • No prior authorization for emergency services
  • Expanded coverage for early retirees
  • Patient-Centered Outcomes Research Institute (PCORI) established
  • Small Business Tax Credits
  • Reinsurance program for retiree coverage
  • Non-discrimination rules for insured plans (but delayed compliance date)

 


2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2018

2011

  • Annual rate review process
  • Medical Loss Ratio (MLR) rules
  • Increased penalty for non-qualified withdrawals from HSAs & MSAs, including over the counter drugs
  • Simple cafeteria plans

 


2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2018

2012

  • Medical Loss Ratio rebates by Aug 1, 2012
  • Patient-Centered Outcomes Research Institute (PCORI) fee
  • Annual dollar limits on Essential health Benefits must be at least $1.25 million for plan years beginning on or after Sep 23, 2011 and before Sep 23, 2012
  • Additional claims and appeals requirements (non-grandfathered plans only)
  • W-2 Reporting of value of employer-sponsored health coverage; report on 2012 W-2s (issued by 1/31/13)
  • Women’s preventive services, coverage with no cost-sharing, for plan years starting on or after Aug 1, 2012
  • Uniform Summary of Benefits and Coverage (SBC), as of the first open enrollment beginning on or after Sep 23, 2012
  • Mid-year material modifications to information in SBC; plan must provide 60-day advance notice to participants
  •  DELAYED: Quality of care reporting

 


2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2018

2013

  • Flexible Spending Accounts – Employees pre-tax contributions capped at $2,500
  • Medicare tax increase for “high earners” (tax on earnings and investment income)
  • No deduction for retiree drug subsidy
  • W-2 reporting of value of employer-sponsored health coverage
  • Exchange Notices to employees by Oct 1
  • Annual dollar limits on Essential Health Benefits must be at least $2 million for plan years beginning on or after Sep 23, 2012 and before Jan 1, 2014
  • Women’s preventive services, coverage with no cost-sharing, for plan years starting on or after Aug 1, 2012
  • Medicare retiree drug subsidy, change in tax treatment
  • Initial open enrollment period for Health Insurance Marketplaces for 2014.  Begins Oct 1, 2013 (through Mar 31, 2014).

 


2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2018

2014

  • Individual Mandate – requires most U.S. citizens and legal residents to have “minimum essential coverage” (MEC) or to pay a tax for failing to have coverage
  • Health Insurance Marketplaces, coverage effective Jan 1, 2014
  • Federal subsidies (health insurance premium tax credits and reduced cost-sharing) for qualifying individuals with household incomes of 100-400% of the federal poverty level (FPL)
  • Employer Shared Responsibility Provisions – DELAYED to 2015
  • Guarantee issue and renewability of insurance in the individual and small group markets and in the Marketplaces
  • Modified community rating, allows insurers to rate only on age (limited to a 3 to 1 ratio), geographic area, family tier and tobacco use (limited to 1.5 to 1 ratio) in the individual and small group market, both in and outside the Marketplaces
  • No annual dollar limits on Essential Health Benefits
  • Wellness plan limits increase – Employers may offer employees wellness rewards of up to 30% (up from 20%) of the total cost of coverage under the employer group health plan; for tobacco cessation wellness programs, reward may be up to 50% of total cost of coverage
  • Coverage of clinical trials; non-grandfathered plans must provide coverage for routine medical costs for participants in clinical trials
  • Nondiscrimination rules – will be effective some period of time after final guidance is issued, and will apply to non-grandfathered insured health plans; likely will be effective in 2014 or possibly 2015.
  • Small business Tax Credits of up to 50% of employer cost of providing employee health insurance; but as of 2014, only if qualifying small employer purchases it through a SHOP  Marketplace
  • Health insurance tax on insurers and re-insurers, starts in 2014 and is fully implemented in 2018; tax is on health insurance carrier’s net premiums
  • Transitional re-insurance fee: Tax on both insured and self-insured group health plans, during 2014-2016; purpose is to raise money to partially reimburse carriers who get more than their share of high claims individuals in non-grandfathered individual policies in the Marketplaces in 2014-2016

 


2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2018

2015

  • Employer Shared Responsibility Provisions: “Large” employers (at least 50 employees) must “Pay or Play”; may be subject to penalties if do not offer coverage that meets affordability and minimum value requirements to at least 95% of employees (& dependents) who work at least 30 hours/week
  • Auto Enrollment. Employers with more than 200 full-time employees must automatically enroll eligible employees in the employer group health plan (but the employee can opt out). Expected to become effective in 2015, but could be later

 


2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2018

2018

  • Cadillac Tax on high-cost insurance.  A 40% excise tax will be imposed on insurers of employer-sponsored health plans if the total annual benefits cost exceeds $10,200 for individual coverage or $27,500 for family coverage (these 2010 thresholds are likely to be higher in 2018).