Tuesday, August 14, 2012

HealthCare Reform Timeline

We have partnered with our colleagues at UBA to provide you with a timeline of changes that will affect employers and group health plans in 2012 and beyond:

2012:

August 1, 2012


  • Minimum Loss Ratio letters (applies only to fully insured plans)

First Plan Year Beginning On or After August 1, 2012

  • First dollar preventive care services for women (not applicable to grandfathered plans; one year moratorium for certain religious institutions)*

First Open Enrollment Beginning after September 23, 2012

  • Uniform Health Plan Summary of Benefits and Coverage (SBC)

2013:

January 1, 2013

  • Employer W-2 reporting for benefits provided during prior year (not applicable to employers that issued fewer than 250 W-2's for 2011)
  • Health FSA contributions limited to $2,500*
  • Increased Medicare health insurance tax withholding on high-income individuals
  • Repeal of employer business deduction for qualified retiree drug programs +

March 1,2013

  • Employee notice requirement re: exchanges (minimal details have been released on this requirement)

July 31, 2013

  • Patient-centered outcomes ("comparative effectiveness") fee due for plan years ending between October 1, 2012 and December 31, 2012
* or start of 2013 plan year, if later
+ 2013 tax year


2014:

Plan Coverage Provisions - Plan Design


  • Pre-existing conditions exclusion not applicable to adults (or children)
  • Employee waiting period for coverage cannot exceed 90 days
  • Annual limits prohibited on essential health benefits
  • Limits on cost-sharing (deductibles and out-of-pocket maximums)*
  • Wellness programs may increase penalty/reward to 30%
  • Clinical trials coverage*

Other Provisions Impacting Employer-Based Coverage

  • Exchanges available to individuals and small employers (employers with fewer than 100 employees, although state may drop the threshold to 50 employees)
  • Qualified Health Plans (QHP's) participating in exchanges may be offered through cafeteria plans
  • Shared responsibility ("play or pay") penalty for employers with 50 or more full-time employees (or full-time employee equivalents) who fail to provide minimum, affordable coverage to full-time employees

Employer Reporting and Notice Requirements

  • Employer reporting: providing minimum essential coverage
  • Employer reporting: furnishing of qualifying and affordable coverage
  • Return filing requirements for employers not offering coverage

Individual Mandate Effective

  • Penalty applies if individual fails to obtain coverage through employer, exchange or a government program
  • Individual subsidies are available up to 4x the federal poverty level

Exchanges

  • State-based Insurance exchanges (some may be run by federal government)
  • Co-ops / multi-state plans / interstate compacts possible
  • Small business health options (SHOP) exchanges available
  • Navigators
  • Initially available only to individuals and small employers (employers with fewer than 100 employees, although state may drop the threshold to 50 employees); states may expand to large employers in 2017
  • Cost sharing available for individuals below 2.5x the federal poverty level

Exchanges - Benefit Designs and Qualified Plans

  • Minimum essential benefits required for exchange plans
  • Optional additional required benefits
  • Qualified plans to offer "metal" levels of coverage (platinum [90%], gold [80%], silver [70%] and bronze [60%]
  • Health care quality rewards via market-based incentives

Insurer Provisions

  • Guaranteed issue*
  • Guaranteed renewability*
  • Modified community-rating ("fair health insurance premium) requirements (small group market only)*
  • Insurance risk pools

Medicaid Expansion (unless state opts out)

Nondiscrimination Requirements

  • Currently applies to self-funded plans
  • Effective date for fully insured plans indefinitely delayed*
  • Will impact ability to provide different eligibility, benefits and premium subsidies to different groups

Automatic Enrollment

  • Applies to employers with more than 200 employees
  • Effective date delayed until at least 2014

Excise on High Cost "Cadillac" Plans (effective 2018)


* = Grandfather rules apply


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