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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