| Effective Date | Issue | Change Due to Health Care Reform |
|---|---|---|
| 1/1/12 | IRS W-2 Requirement | Aggregate cost of employer sponsored health coverage to be reported on IRS Form W-2. Effective January 1, 2011 on a voluntary basis and mandatory effective January 1, 2012. First W-2s will be issued in 2013. |
| Beginning on or after 9/23/12 | Uniform Summary of Benefits | Plan sponsors of self-insured plans and health insurance issuers must provide a uniform summary of benefits and coverage to all employees and new enrollees beginning on or after September 23, 2012. |
| Beginning on or after 9/23/12 | Notice of Material Change | 60-day advance notice of material modifications of plan or coverage that is not included in most recent Uniform Summary of Benefits. Effective beginning on or after September 23, 2012. |
| Plan years beginning after 3/23/12 | Quality of Care/Cost Reporting | Group Health Plans and health insurance issuers must provide a report to HHS and those enrolled in a plan, about plan benefits, costs or designs that provide incentives for certain cost-reduction strategies. (Non-grandfathered plans only). Effective for plan years beginning after March 23, 2012 or later as may directed by the Department of Health and Human Services. |
| Plan years ending after 9/30/12 | Comparative Clinical Effectiveness Research Fee | Comparative Clinical Effectiveness Research Fee imposed to fund the newly formed “Patient-Centered Outcomes Research Institute,” which will analyze the effectiveness of treatments, medications, etc. Effective for plan years ending after September 30, 2012. |
| Effective Date | Issue | Change Due to Health Care Reform |
|---|---|---|
| 1/1/13 | Health Reimbursement Plans | Maximum Health Flexible Spending Account contribution is capped at $2,500. Effective January 1, 2013. |
| 1/1/13 | Individual Income Tax | Individual income tax of 3.8% imposed on unearned income above certain thresholds. Effective January 1, 2013. |
| 1/1/13 | Payroll Tax | Payroll tax increase from 1.45% to 2.35% imposed on wages above certain thresholds. Effective January 1, 2013. |
| Required compliance TBD | Notice of Exchanges, Subsidies | Plan sponsors must provide employees information about Exchange and availability of Federal subsidies.**January 24, 2013 the DOL delayed implementation of this provision and employers are no longer required to comply by March 1. Compliance date is to be determined.** |
| Effective Date | Issue | Change Due to Health Care Reform |
|---|---|---|
| 1/1/14 | California Exchange | California Exchange becomes operational to sell “qualified health plans”. Individuals and small employers (<50) may purchase group insurance on the California Exchange. Effective January 1, 2014. |
| 1/1/14 | Individual Mandate | Individuals required to maintain “minimum essential health coverage” or pay a penalty. Effective January 1, 2014. |
| 1/1/14 | Federal Subsidies for Individuals | Federal subsidies available for certain individuals with household income below 400% of the Federal Poverty Level. Effective January 1, 2014. |
| 1/1/14 | Employer Mandate | Large employers subject to penalty if employees with household income below 400% Federal Poverty Level purchase health insurance on the California Exchange and receive a Federal subsidy. Effective January 1, 2014. |
| 1/1/14 | IRS Reporting by Employers | New IRS reporting by employers regarding health plans and penalties. Effective January 1, 2014. |
| Plan years beginning on or after 1/1/14 | Waiting Periods | A Group Health Plan may not impose waiting periods exceeding 90 days. Effective for plan years beginning on or after January 1, 2014. |
| Plan years beginning on or after 1/1/14 | Annual Limits | Annual dollar limits on essential health benefits are prohibited. Effective for plan years beginning on or after January 1, 2014. |
| Plan years beginning on or after 1/1/14 | Preexisting Conditions | Preexisting condition exclusions are prohibited regardless of age. Effective for plan years beginning on or after January 1, 2014. |
| Plan years beginning on or after 1/1/14 | Wellness Programs | Rewards for Wellness Programs may be increased to 30% of employee-only coverage. Effective for plan years beginning on or after January 1, 2014. |
| Plan years beginning on or after 1/1/14 | Coverage for Children | Coverage for children, including adult non-dependent children, must be offered even if eligible for coverage at another employer. Effective for plan years beginning on or after January 1, 2014. |
| Plan years beginning on or after 1/1/14 | Denials – Clinical Trials | No denials for approved clinical trials or payment of routine costs (non-grandfathered plans only). Effective for plan years beginning on or after January 1, 2014. |
| Effective Date | Issue | Change Due to Health Care Reform |
|---|---|---|
| 1/1/17 | California Exchange | Large employers (>100) may participate on the California Exchange if permitted by the State. Effective January 1, 2017. |
| Effective Date | Issue | Change Due to Health Care Reform |
|---|---|---|
| 1/1/18 | Excise Tax | 40% Excise tax imposed on health insurance premiums exceeding $10,200 for single coverage and $27,500 for family coverage. Effective January 1, 2018. |
| Glocal Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Clients are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the clients’ business activities. |