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.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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