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Comprehensive health care implementation timeline
- 2010
- Change in tax treatment for over-age dependent coverage
- Accounting impact of change in Medicare retiree drug subsidy tax treatment
- Early retiree medical reinsurance
- Medicare prescription drug “donut hole” beneficiary rebate
- Break time/private room for nursing moms
- 2011
- Extension of coverage for children to 26 (grandfathered plans may limit to children without access to other employer coverage, other than parent’s coverage)*
- No lifetime dollar limits*
- Restricted annual dollar limits, phased amounts until 2014*
- No pre-existing condition limitations for enrollees up to age 19*
- No rescissions*
- No health FSA/HRA/HSA reimbursement for non-prescribed drugs
- Increased penalties for non-qualified HSA distributions
- Additional standards for new or “non-grandfathered” health plans, including mandatory preventive care in network with no cost-sharing (nondiscrimination provisions for insured plans have been delayed)
- Voluntary long-term care “CLASS” program slated to start (implementation TBD)
- Pharmaceutical manufacturers’ fees start
- Medicare, Medicare Advantage benefit and payment reform
- Insurers subject to medical loss ratio rules
* Applies to all plans, including “grandfathered” plans, effective for plan years beginning on or after Sept. 23, 2010 (Jan. 1, 2011, for calendar year plans).
** Applies to all plans, including grandfathered plans, effective for plan years beginning on or after Jan. 1, 2014.
- 2012
- Employers must distribute uniform benefit summaries to participants
- Employers must provide 60-day advance notice of material modifications
- Group health plan fees begin
- 2013
- $2,500 health FSA contribution cap (indexed)
- Form W-2 reporting for 2012 health coverage
- Medical device manufacturers’ fees start
- Higher Medicare payroll tax on wages exceeding $200,000/ individual; $250,000/couples
- New tax on net investment income for taxpayers with incomes exceeding $200,000/ individual; $250,000/couples
- Change in Medicare retiree drug subsidy tax treatment takes effect
- 2014
- Health insurance exchanges
- Individual coverage mandate
- Financial assistance for exchange coverage of low-income individuals
- Medicaid expansion
- HIPAA wellness limit increases
- Shared responsibility penalties
- Free-choice vouchers
- Additional reporting and disclosure
- Auto enrollment of full-time employees (effective TBD)
- Extension of coverage for children to age 26, regardless of other coverage**
- No annual dollar limits**
- No pre-existing condition limits**
- No waiting period over 90 days**
- Additional new standards for new or “non-grandfathered” health plans, including limited cost-sharing
- Health insurance industry fees begin
** Applies to all plans, including grandfathered plans, effective for plan years beginning on or after Jan. 1, 2014.
- 2018
- Excise tax on “high cost” or Cadillac plans