Health Care Reform – Implementation Timeline For Employers (Subject To Change As Additional Guidance Is Issued)

[author: Jewelie Grape]

Here’s a brief timeline highlighting important health care reform dates for employers…I expect some dates will change as 2014 draws nearer, and I will update the timeline accordingly.

9/23/12 – Group health plans must provide all eligible employees a standard Summary of Benefits and Coverage so members can compare medical plans.

12/31/12 – Form W-2 Reporting (2012 tax year). Most employers that issued 250 or more W-2’s in 2011 must report the value of health benefits in Box 12 (Code DD) on the 2012 Form W-2, issued in January, 2013. Certain organizations, such as churches, are excluded from this requirement for 2012.

1/1/13 – Maximum contribution limit of $2,500 for health care flexible spending accounts goes into effect for plan years beginning on or after this date.

1/1/13 – Additional Medicare tax of .9% assessed on an employee’s wages over $200,000 (the employee-paid Medicare tax increases from 1.45% to 2.35%).

3/1/13 – Employer Provided Notice of Exchange. Employers must provide a notice to employees informing them of the availability of state health insurance exchanges and how such exchanges can be accessed.

1/1/14 –

-     Pay or Play/Employer Shared Responsibility goes into effect. Employers with 50 or more full-time equivalent employees must offer affordable, minimum essential health coverage to their full time employees or pay a penalty.

-     Enroll or Pay/Individual Mandate goes into effect. Most individual taxpayers must have health coverage or purchase health coverage through state or federal health insurance exchange or pay a penalty.

-     Wellness Incentives. Group health plans are allowed to increase permitted wellness incentives from 20 percent of premium costs to 30 percent of premium costs.

-     Pre-existing Conditions Exclusions. Group health plans cannot impose exclusions on coverage for pre-existing conditions.

-     Annual Dollar Limits. Group health plans cannot not impose annual dollar limits on essential health benefits (before 2014, restricted limits apply).

-     Non-discrimination. Fully-insured group health plans may not discriminate in favor of highly compensated employees (this already applies to self-insured health plans).

-     Automatic Enrollment. Large employers (those with 200 or more full-time employees) must automatically enroll new employees in their group health plan.

1/1/18 – “Cadillac Tax” goes into effect. Plans will be required to pay a 40 percent excise tax (the cost of which may be passed on to the employer) if they exceed annual inflation-adjusted cost thresholds beginning at $10,200 for individual coverage and $27,500 for family coverage.