Health Care Reform Timeline


  • 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 benefits (1)
  • Restricted annual dollar limits on essential health benefits, phased amounts until 20141
  • No pre-existing condition limitations for enrollees up to age 191 and no rescissions (1)
  • 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 plans (3)
  • 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 services (5)

(4)  A temporary exemption applies to certain categories of employers

(5)  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 mandate
  • Financial assistance for exchange coverage of lower-income individuals
  • States Medicaid expansion (possibly only some states)
  • Dependent coverage to age 26 for any covered employee’s child (2)
  • No annual dollar limits on essential health benefits (2) (generally banning standalone HRAs)
  • No pre-existing condition limits (2)
  • No waiting period over 90 days (2)
  • Wellness limit increase allowed (2)
  • 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.


  • Employer Mandate (Brief on Delay)
  • Temporary reinsurance fees first due in late 2014/early 2015
  • Additional employee-specific reporting and disclosure of 2014 coverage



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