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