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

• Dependent coverage to 26 (grandfathered plans may limit to children without access to other employer employer coverage, other than parent's coverage)¹
• No lifetime dollar limits¹ 
• Restricted annual dollar limits, phased amounts until 2014¹ 
• No pre-existing condition limitations for enrollees up to age 19¹ 
• No rescissions¹ 
• 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 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 to begin 
• 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

2012

• Employers to distribute uniform summary of benefits and coverage (SBC)³ 
• Employers to provide 60-day advance notice of material modifications for mid-year changes³
• Form W-2 reporting for health coverage (tract in 2012 for W-Z form provided in early 2013)⁴
• Comparative effectiveness group health plan fees begin
• Coverage for additional women's preventive care services begins (plan years on or after August 1, 2012)

³ Delayed until regulations issued/date TBD

⁴ A temporary exemption applies to employers filling fewer than 250 Forms W-2.

2013

• $2,500 health FSA contribution cap (indexed)
• Employers notify employees about exchanges
• 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
• Auto-enrollment likely to begin in 2014
• Exchanges initial open enrollment period to begin

2014

• Health insurance exchanges
• Individual coverage mandate
• Financial assistance for exchange coverage of lower-income individuals
• Medicaid expansion
• HIPAA wellness limit
• Employer shared responsibility
• Additional reporting and disclosure
• Dependent coverage to age 26 for any covered employee’s child² 
• No annual dollar limits² 
• No pre-existing condition limits² 
• No waiting period over 90 days² 
• Additional new standards for new or "non-grandfathered" health plans, including limited cost-sharing and deductibles
• Health insurance industry fees begin

² Applies to all plans, including grandfathered plans, effective for plan years beginning on or after Jan. 1, 2014.

2018

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

© 2011 Mercer. This is for informational purposes only, and is not intended to be used as legal advice.