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

• 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

2012

•  

• 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

⁵  Applies to nongrandfathered plans

2013

• $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 

2014

• Health insurance exchanges
• Individual coverage mandate
• Financial assistance for exchange coverage of lower-income individuals
• States Medicaid expansion (possibly only some states)
• Employer shared responsibility
• 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 

² 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.

2015

• Temporary reinsurance fees first due in late 2014/early 2015
• Additional employee-specific reporting and disclosure of 2014 coverage

2018

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

© 2013 Mercer. This is for informational purposes only, and is not intended to be used as legal advice.