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AFFORDABLE CARE ACT

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ACA Timeline

2010

• Annual limit restrictions for essential health benefits for plan years beginning on or after September 2010
  
• Adult child coverage required to age 26 regardless of martial status, residency or school attendance for plan years beginning on or after September 2010
  
• Lifetime benefit limit restrictions for essential health benefits for plan years beginning on or after September 2010
  
• Elimination of pre-existing condition exclusions for covered children under age 19 for plan years beginning on or after September 2010
  
• Preventive care coverage requirements for plan years beginning on or after September 2010
  
• Health care plan rescission restriction for plan years beginning on or after September 2010
  
• Implementation of internal and external appeals process for plan years beginning on or after September 2010 (does not apply to grandfathered plans)
  

2011

• Penalty for non-qualified health savings account withdrawals, increase in excise tax from 10% to 20% effective January 2011
  
• Elimination of reimbursement of over-the-counter drugs without a prescription for flexible spending accounts, health savings accounts or health reimbursement arrangements (tax years beginning January 2011)
  

2012

• Employer W-2 Form reporting requirements for cost of health care coverage (tax years beginning January 2012)
  
• Uniform explanation of coverage requirement also known as the Summary of Benefits and Coverage. Employer required to provide participants a summary of benefits and coverage explanation prior to enrollment (open enrollment periods or plan years after September 2012)
  
• Fee per covered individual charged to health plan sponsors and insurance companies to fund the Patient-Centered Outcomes Research Institute (PCORI) (policy or plan years ending after September 2012; fee is first due July 2013 and fee ends in 2019.)
  

2013

• Flexible spending account annual employee contribution limit capped at $2,500 effective January 2013
  
• Additional Medicare payroll tax for high-income individuals effective January 2013
  
• Medicare Part D retiree drug subsidy loses tax-exempt status effective January 2013
  
• Employee notice of coverage options in the Marketplace (exchanges) before October 2013
  

2014

• Individual health care coverage mandate or penalty tax for no coverage as of January 2014
  
• No cost sharing for routine preventive services as of January 2014. No cost sharing for women's preventive services including contraceptives as of August 2014 (does not apply to grandfathered plans)
  
• Elimination of annual limits in health plans except for annual limits on specific covered benefits that are not essential health benefits as of January 2014
  
• Plans must limit annual participant out-of-pocket maximum for In-network services to the limit imposed on health savings account compatible high-deductible health plans for plan years beginning on or after January 2014 (does not apply to grandfathered plans)
  
• Qualified health plans offered through an exchange and insurers in the small and individual markets must include essential health benefits and meet a specified actuarial benefit value as of January 2014 (does not apply to grandfathered plans)
  
• Creation of health exchanges, marketplaces that allow individuals and eligible employers to purchase health insurance as of January 2014
  
• Elimination of pre-existing condition exclusions for all participants as of January 2014
  
• Waiting period limitation, maximum of 90 days as of January 2014
  
• Increases in maximum wellness incentives from 20% to 30% of the cost of coverage with possibility of increase to 50% as of January 2014
  
• Coverage of routine health care in approved clinical trials as of January 2014 (does not apply to grandfathered plans)
  
• Fee charged to health insurance issuers and certain health plan administrators on behalf of self-insured group health plans for transitional reinsurance program for years 2014-2016
  
• HIPAA Certification: employer group health plans must certify requirements for HHS rules on electronic transactions between providers and health plans by December 31, 2015. Self-insured plans must obtain a Health Plan Identifier Number (HPID) by November 5, 2014. This requirement has been delayed until further notice.
  

2015

• Large employers with 50 or more employees must offer coverage to full-time employees (30 hours or more per week) or pay penalty; coverage must be affordable and meet minimum standards (voluntary compliance in 2014; required in 2015)
  
  • Final rules for 2015 provide that the employer responsibility provision will generally apply to employers with 100 or more full-time employees starting in 2015 and employers with 50 to 99 full-time employees in 2016
    
  • To avoid a payment for failing to offer health coverage, employers need to offer coverage to 70% of their full-time employees in 2015 and 95% in 2016 and beyond.
    
• Flexible spending account annual employee contribution limit capped at $2,550 effective January 2015
  

2018

• Excise tax on high-cost group health plans: tax imposed on value of "excess" coverage in January 2018. Coverage under employer group health plans that exceeds annual cost of $10,200 for single coverage or $27,500 for family coverage, to be adjusted for inflation, will be subject to an excise tax.
  

Resource: IFEBP