PPACA Timeline

Effective Date Issue Change Due to Health Care Reform
1/1/12 IRS W-2 Requirement Aggregate cost of employer sponsored health coverage to be reported on IRS Form W-2. Effective January 1, 2011 on a voluntary basis and mandatory effective January 1, 2012. First W-2s will be issued in 2013.
Beginning on or after 9/23/12 Uniform Summary of Benefits Plan sponsors of self-insured plans and health insurance issuers must provide a uniform summary of benefits and coverage to all employees and new enrollees beginning on or after September 23, 2012.
Beginning on or after 9/23/12 Notice of Material Change 60-day advance notice of material modifications of plan or coverage that is not included in most recent Uniform Summary of Benefits. Effective beginning on or after September 23, 2012.
Plan years beginning after 3/23/12 Quality of Care/Cost Reporting Group Health Plans and health insurance issuers must provide a report to HHS and those enrolled in a plan, about plan benefits, costs or designs that provide incentives for certain cost-reduction strategies. (Non-grandfathered plans only). Effective for plan years beginning after March 23, 2012 or later as may directed by the Department of Health and Human Services.
Plan years ending after 9/30/12 Comparative Clinical Effectiveness Research Fee Comparative Clinical Effectiveness Research Fee imposed to fund the newly formed “Patient-Centered Outcomes Research Institute,” which will analyze the effectiveness of treatments, medications, etc. Effective for plan years ending after September 30, 2012.
Effective Date Issue Change Due to Health Care Reform
1/1/13 Health Reimbursement Plans Maximum Health Flexible Spending Account contribution is capped at $2,500. Effective January 1, 2013.
1/1/13 Individual Income Tax Individual income tax of 3.8% imposed on unearned income above certain thresholds. Effective January 1, 2013.
1/1/13 Payroll Tax Payroll tax increase from 1.45% to 2.35% imposed on wages above certain thresholds. Effective January 1, 2013.
Required compliance TBD Notice of Exchanges, Subsidies Plan sponsors must provide employees information about Exchange and availability of Federal subsidies.**January 24, 2013 the DOL delayed implementation of this provision and employers are no longer required to comply by March 1. Compliance date is to be determined.**
Effective Date Issue Change Due to Health Care Reform
1/1/14 California Exchange California Exchange becomes operational to sell “qualified health plans”. Individuals and small employers (<50) may purchase group insurance on the California Exchange. Effective January 1, 2014.
1/1/14 Individual Mandate Individuals required to maintain “minimum essential health coverage” or pay a penalty. Effective January 1, 2014.
1/1/14 Federal Subsidies for Individuals Federal subsidies available for certain individuals with household income below 400% of the Federal Poverty Level. Effective January 1, 2014.
1/1/14 Employer Mandate Large employers subject to penalty if employees with household income below 400% Federal Poverty Level purchase health insurance on the California Exchange and receive a Federal subsidy. Effective January 1, 2014.
1/1/14 IRS Reporting by Employers New IRS reporting by employers regarding health plans and penalties. Effective January 1, 2014.
Plan years beginning on or after 1/1/14 Waiting Periods A Group Health Plan may not impose waiting periods exceeding 90 days. Effective for plan years beginning on or after January 1, 2014.
Plan years beginning on or after 1/1/14 Annual Limits Annual dollar limits on essential health benefits are prohibited. Effective for plan years beginning on or after January 1, 2014.
Plan years beginning on or after 1/1/14 Preexisting Conditions Preexisting condition exclusions are prohibited regardless of age. Effective for plan years beginning on or after January 1, 2014.
Plan years beginning on or after 1/1/14 Wellness Programs Rewards for Wellness Programs may be increased to 30% of employee-only coverage. Effective for plan years beginning on or after January 1, 2014.
Plan years beginning on or after 1/1/14 Coverage for Children Coverage for children, including adult non-dependent children, must be offered even if eligible for coverage at another employer. Effective for plan years beginning on or after January 1, 2014.
Plan years beginning on or after 1/1/14 Denials – Clinical Trials No denials for approved clinical trials or payment of routine costs (non-grandfathered plans only). Effective for plan years beginning on or after January 1, 2014.
Effective Date Issue Change Due to Health Care Reform
1/1/17 California Exchange Large employers (>100) may participate on the California Exchange if permitted by the State. Effective January 1, 2017.
Effective Date Issue Change Due to Health Care Reform
1/1/18 Excise Tax 40% Excise tax imposed on health insurance premiums exceeding $10,200 for single coverage and $27,500 for family coverage. Effective January 1, 2018.
Glocal Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Clients are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the clients’ business activities.