HEALTH CARE REFORM TIMELINE

2010    

2011

2013

2014

2015

Health plans that provide dependent coverage must make coverage available for dependents up to age 26

Medical loss ratio (MLR) rules apply to health insurer premium spending (consumer rebates must be paid by Aug. 1 each year starting in 2012)

Improvements on HIPAA’s electronic transaction rules start to be phased in

Individuals must obtain health insurance coverage or pay a penalty (some exemptions apply)

Large employers must offer coverage to FT employees (that is affordable and provides minimum value) or pay a penalty (delayed for one year, until 2015; payments will not apply for 2014)

Uninsured individuals with pre-existing conditions can obtain health insurance through a high-risk health insurance pool program

Employers must report health coverage costs on Form W-2 (optional for 2011; mandatory for later years; delayed for further guidance for small employers)

Employers must provide a notice to employees regarding the insurance exchanges by Oct. 1, 2013

Health insurance Exchanges to be established for individuals and small employers

2018
High-cost plan excise tax established in 2018

HHS established a website for individuals  to identify affordable health insurance options in their state (www.healthcare.gov)  

OTC medicine and drugs are “qualified medical expenses” for HSAs, FSAs and HRAs only if prescribed (except insulin)

Medicare Part D subsidy deduction eliminated

Health insurance companies will not be able to discriminate against individuals based on health status

Future
Automatic enrollment rules for employers with more than 200 FT employees

Early retiree reinsurance program provides reimbursement for a portion of the cost of providing health coverage for early retirees. Program was available for claims incurred before Jan. 1, 2012

Simple cafeteria plan provides small businesses with an easier way to sponsor a cafeteria plan

Income threshold for claiming itemized deduction for medical expenses increased

Individual health care tax credits available for certain individuals

Lifetime dollar limits on essential health benefits are prohibited. Annual dollar limits are restricted until 2014 when all annual dollar limits on essential health benefits are prohibited

Medicare Part D drug discounts start to be phased in for beneficiaries in the “donut hole” until the coverage gap is filled in 2020

Medicare hospital insurance tax rate for high wage workers increased

Health insurance provider fee and reinsurance fee take effect and increase annually (reinsurance fee effective 2014-2016)

Pre-existing condition exclusions are eliminated for children under age 19

Penalty tax increases on withdrawals from HSAs (prior to age 65) and Archer MSAs not used for qualified medical expenses

Medical device excise tax established

Health plans cannot impose waiting periods longer than 90 days

Non-grandfathered health plans must cover certain preventive care services without cost-sharing

Free annual wellness visit for Medicare beneficiaries and elimination of cost sharing for preventive care services

 Salary reduction contributions to FSAs are limited to $2,500

No limits on annual dollar value of essential health benefits

Rescissions are prohibited in most cases; plan coverage may not be retroactively cancelled without prior notice to the enrollee

2012

By Dec. 31, 2013, employers must certify compliance with certain HIPAA electronic transactions

Pre-existing condition exclusions prohibited for adults

Fully insured group health plans must satisfy nondiscrimination rules regarding participation and benefit eligibility  (delayed for future regulations)

Plans must provide SBC with the open enrollment period or plan year beginning on or after Sept. 23, 2012 (depending on type of enrollment)

Insured plans in the small group and individual market must provide comprehensive benefits coverage (does not apply to grandfathered plans)

Plans and issuers must adopt an improved internal claims and appeals process and comply with external review requirements (some rules were delayed until plan years beginning on or after Jan. 1, 2012)

For plan years beginning on or after Aug. 1, 2012, plans and issuers must cover additional preventive care services for women without cost-sharing. Exceptions to contraceptive coverage apply to religious employers

Reforms related to the allocation of insurance risk through reinsurance, risk corridors and risk adjustment become effective

First phase of the small business health care tax credit

For plan years ending on or after Oct. 1, 2012, issuers and self-insured health plans must pay PCORI/comparative effectiveness research fees

Some non-grandfathered health plans subject to cost-sharing limits

Rebates for the Medicare Part D “donut hole”
sent to eligible enrollees

Second phase of small business tax credit