Health care reform timeline

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Health care reform timeline: Key elements of health reform for employers





  • 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





  • No lifetime dollar limits on essential health benefits1 
  • Restricted annual dollar limits on essentail health benefits, phased amounts until 20141 
  • No pre-existing condition limitations for enrollees up to age 191  and no recissions1 
  • 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 preventive care in network with no cost-sharing appeal and external review, provider choice and non-discrimination provisions for insured plans3 
  • Income-based Medicare Part D premiums
  • Pharmaceutical importers and manufacturers' fees start
  • Medicare, Medicare Advantage benefit and payment reforms 
  • Insurers subject to medical loss ratio rules


1 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).

3 Delayed until regulations issued/date TBD




  • Employers to distribute uniform summary of benefits and coverage (SBC) to participants (deadlines vary with group of recipients) 
  • 60-day advance notice of mid-year material modifications to SBC content
  • Form W-2 reporting for health coverage (track in 2012 for W-2 form provided in early 2013)4
  • Coverage for additional women's preventive care services5 


4 A temporary exemption applies to certain categories of employers

 Applies to nongrandfathered plans




  • $2,500 per plan year health FSA contribution cap (plan years on or after January 1, 2013)
  • Comparative effectiveness group health plan fees first due
  • Annual dollar limits on essential health benefits cannot be lower than $2 million
  • Employers notify employees about exchanges by Oct. 1, 2013
  • Medical device manufacturers' fees start
  • Higher Medicare payroll tax on wages exceeding $200,000/individual; $250,000/couples
  • Change in Medicare retiree drug subsidy tax treatment takes effect  
  • Health Insurance exchanges initial open enrollment period 





  • Health insurance exchanges
  • Individual coverage mandate6
  • Financial assistance for exchange coverage of lower-income individuals
  • States Medicaid expansion (states opting to expand)
  • Dependent coverage to age 26 for any covered employee’s child2 
  • No annual dollar limits on essential health benefits2 (generally banning standalone HRAs)
  • No pre-existing condition limits2 
  • No waiting period over 90 days2 
  • Wellness limit inscrease allowed2 
  • Health insurance industry fees
  • Additional standards for  non-grandfathered health plans, including limits on out-of-pocket maximums, 
    provider nondiscrimination, and coverage of routine medical costs of clinical trial participants
  • Small market, non-grandfathered insured plans must cover essential health benefits with limited deductibles (initially $2,000/individual, $4,000/family), using a form of community rating
  • Insurers must apply guaranteed issue and renewability to non-grandfathered plans of all sizes
  • Auto enrollment sometime after 2014


Applies to all plans, including grandfathered plans, effective for plan years beginning on or after Jan. 1, 2014.

3 Delayed until regulations issued /date TBD.

6 A temporary exemption applies to employees of employers with non-calendar-year plans





  • Temporary reinsurance fees first due in late 2014/early 2015
  • Possible additional reporting and disclosure
  • Employer shared responsibility7  


7 Effective 2015 for applicable large employers with 100 or more employees; effective 2016 for applicable large employers with 50 or more employees



  • 40% excise tax on "high cost" or Cadillac coverage




© 2014 Mercer. This is for informational purposes only, and is not intended to be used as legal advice.



Health care reform Timeline