Affordable Care Act Timeline FINAL
Content
The Affordable Care Act: Important Dates for Employers
July 1, 2012
Claims and Appeals Processes* By July 1, 2012, self-insured group health plans must contract with at least three Independent Review Organizations (IROs). These plans were required to have contracted with two IROs by January 1, 2012. Other requirements related to internal and external claims processes generally went into effect in part for plan years beginning on or after July 1, 2011 and in part by plan years beginning on or after January 1, 2012.
August 1, 2012
Medical Loss Ratio (MLR Rebates) If an insurer’s MLR is less than 80% (or 85% in the large group market), insured group health plans must receive MLR rebates. Plan sponsors must distribute rebates in compliance with ERISA plan asset rules. Preventive Health Services for Women* For plan years beginning on or after August 1, 2012, group health plans must provide women’s preventive health services with no cost-sharing requirements.
September 23, 2012
Summary of Benefits and Coverage (SBC) Insurers and self-insured group health plans must provide SBCs for annual enrollments beginning on or after September 23, 2012 and for other enrollments and upon request for plan years beginning on or after September 23, 2012.
January 1, 2013
Flexible Spending Account (FSA) Annual Limit For plan years beginning on or after January 1, 2013, $2,500 limit applies to salary reduction contributions to a health care FSA. Medicare Tax Increase Medicare tax on wages increases by 0.9% and a new 3.8% Medicare tax will be imposed on unearned income. These taxes apply to high-income earners only (i.e., those earning $200,000 if filing single, $250,000 if married filing jointly, and $125,000 if married filing separately). Retiree Prescription Drug Expenses No deductions allowed for employers for subsidized retiree prescription drug expenses.
January 31, 2013
Form W-2 Reporting for Tax year 2012 Employers must include the value of group health coverage provided to employees on Form W-2, beginning with the 2012 tax year. (Requirement does not apply to employers who issued fewer than 250 Forms W-2 in preceding calendar year.)
March 1, 2013
Employee Notice of Exchange Employers must provide current employees with a notice describing the availability of Exchange coverage. Notice must be provided upon hire for employees hired after March 1, 2013.
The Affordable Care Act: Important Dates for Employers
July 31, 2013
Comparative Clinical Effectiveness Research Fees Fee payments are due for self-insured group health plans and insurers and are calculated per covered life. For plan years ending on or after October 1, 2012, fee is $1. For plan years ending on or after October 1, 2013 and before October 1, 2019, fee is $2 per covered life.
December 31, 2013
HIPAA Certification Employer group health plans must certify that the plan’s data and information systems are in compliance with HHS rules for certain electronic transactions.
January 1, 2014
Annual Dollar Limits and Waiting Periods/ Pre-existing Condition Exclusions For plan years beginning on or after January 1, 2014, employer group health plans may not impose annual dollar limits on essential health benefits, impose waiting periods of longer than 90 days, or impose pre-existing condition exclusions. “Play or Pay” Employer Shared Responsibility Employers (with 50 or more FTEs and/or equivalents) must offer affordable, minimum essential coverage or be subject to tax penalties. “Play or Pay” Individual Mandate Most individual taxpayers must have minimum essential coverage or be subject to tax penalties. Wellness Incentives For plan years beginning on or after January 1, 2014, permitted wellness incentive increases from 20% of the cost of coverage to 30%.
Expected January 1, 2014
Automatic Enrollment Employers with more than 200 full-time employees must automatically enroll new employees in the employer’s group health plan. Pending guidance may impact effective date. Nondiscrimination Rule* Insured employer group health plans may not discriminate in favor of highly compensated employees. Pending guidance may impact effective date.
January 1, 2018
Excise Tax on High-Cost Plans (“Cadillac Tax”) If coverage under a group health plan exceeds certain thresholds (anticipated in 2018 to be $10,200 for single coverage and $27,500 for family coverage, each to be adjusted for inflation), an insurer, plan administrator or employer will be subject to 40% excise tax on amount of excess benefit.
Unspecified Date
Quality of Care Reporting* An annual report must be provided by employer group health plans to disclose information of plan benefits and reimbursement structures that improve health outcomes. Regulations have not yet been issued and compliance is delayed until such time.
*Does not apply to grandfathered group health plans. ADP does not give legal advice as part of its services. This document provides general information regarding its subject matter and should not be construed as providing legal advice. This material is made available for informational purposes only and is not a substitute for legal advice or your professional judgment. You should review applicable law in your jurisdiction and consult experienced counsel for legal or tax advice. © 2012 ADP, Inc. ADP and the ADP Logo are registered trademarks of ADP, Inc. In the Business of Your Success is a service mark of ADP, Inc., Modified: September 2012
July 1, 2012
Claims and Appeals Processes* By July 1, 2012, self-insured group health plans must contract with at least three Independent Review Organizations (IROs). These plans were required to have contracted with two IROs by January 1, 2012. Other requirements related to internal and external claims processes generally went into effect in part for plan years beginning on or after July 1, 2011 and in part by plan years beginning on or after January 1, 2012.
August 1, 2012
Medical Loss Ratio (MLR Rebates) If an insurer’s MLR is less than 80% (or 85% in the large group market), insured group health plans must receive MLR rebates. Plan sponsors must distribute rebates in compliance with ERISA plan asset rules. Preventive Health Services for Women* For plan years beginning on or after August 1, 2012, group health plans must provide women’s preventive health services with no cost-sharing requirements.
September 23, 2012
Summary of Benefits and Coverage (SBC) Insurers and self-insured group health plans must provide SBCs for annual enrollments beginning on or after September 23, 2012 and for other enrollments and upon request for plan years beginning on or after September 23, 2012.
January 1, 2013
Flexible Spending Account (FSA) Annual Limit For plan years beginning on or after January 1, 2013, $2,500 limit applies to salary reduction contributions to a health care FSA. Medicare Tax Increase Medicare tax on wages increases by 0.9% and a new 3.8% Medicare tax will be imposed on unearned income. These taxes apply to high-income earners only (i.e., those earning $200,000 if filing single, $250,000 if married filing jointly, and $125,000 if married filing separately). Retiree Prescription Drug Expenses No deductions allowed for employers for subsidized retiree prescription drug expenses.
January 31, 2013
Form W-2 Reporting for Tax year 2012 Employers must include the value of group health coverage provided to employees on Form W-2, beginning with the 2012 tax year. (Requirement does not apply to employers who issued fewer than 250 Forms W-2 in preceding calendar year.)
March 1, 2013
Employee Notice of Exchange Employers must provide current employees with a notice describing the availability of Exchange coverage. Notice must be provided upon hire for employees hired after March 1, 2013.
The Affordable Care Act: Important Dates for Employers
July 31, 2013
Comparative Clinical Effectiveness Research Fees Fee payments are due for self-insured group health plans and insurers and are calculated per covered life. For plan years ending on or after October 1, 2012, fee is $1. For plan years ending on or after October 1, 2013 and before October 1, 2019, fee is $2 per covered life.
December 31, 2013
HIPAA Certification Employer group health plans must certify that the plan’s data and information systems are in compliance with HHS rules for certain electronic transactions.
January 1, 2014
Annual Dollar Limits and Waiting Periods/ Pre-existing Condition Exclusions For plan years beginning on or after January 1, 2014, employer group health plans may not impose annual dollar limits on essential health benefits, impose waiting periods of longer than 90 days, or impose pre-existing condition exclusions. “Play or Pay” Employer Shared Responsibility Employers (with 50 or more FTEs and/or equivalents) must offer affordable, minimum essential coverage or be subject to tax penalties. “Play or Pay” Individual Mandate Most individual taxpayers must have minimum essential coverage or be subject to tax penalties. Wellness Incentives For plan years beginning on or after January 1, 2014, permitted wellness incentive increases from 20% of the cost of coverage to 30%.
Expected January 1, 2014
Automatic Enrollment Employers with more than 200 full-time employees must automatically enroll new employees in the employer’s group health plan. Pending guidance may impact effective date. Nondiscrimination Rule* Insured employer group health plans may not discriminate in favor of highly compensated employees. Pending guidance may impact effective date.
January 1, 2018
Excise Tax on High-Cost Plans (“Cadillac Tax”) If coverage under a group health plan exceeds certain thresholds (anticipated in 2018 to be $10,200 for single coverage and $27,500 for family coverage, each to be adjusted for inflation), an insurer, plan administrator or employer will be subject to 40% excise tax on amount of excess benefit.
Unspecified Date
Quality of Care Reporting* An annual report must be provided by employer group health plans to disclose information of plan benefits and reimbursement structures that improve health outcomes. Regulations have not yet been issued and compliance is delayed until such time.
*Does not apply to grandfathered group health plans. ADP does not give legal advice as part of its services. This document provides general information regarding its subject matter and should not be construed as providing legal advice. This material is made available for informational purposes only and is not a substitute for legal advice or your professional judgment. You should review applicable law in your jurisdiction and consult experienced counsel for legal or tax advice. © 2012 ADP, Inc. ADP and the ADP Logo are registered trademarks of ADP, Inc. In the Business of Your Success is a service mark of ADP, Inc., Modified: September 2012
