Health Care Reform Timeline

By Staff Report

Nov. 20, 2012


Flexible spending accounts—Contributions to FSAs are capped at $2,500.

Medicare payroll taxes and Retiree Drug Subsidy—Employees making more than $200,000 (or $250,000 for joint filers) will pay a higher Medicare tax. Employers can no longer take an income tax deduction for Medicare Part D retiree drug subsidies.

Employer notifications—Employers must notify employees of state health insurance exchanges, whether an employer’s plan meets minimum coverage requirements and how to access information regarding premium subsidies that may be available for exchange-based coverage.

W-2 reporting—Large employers must report the cost of employer-provided health care coverage on their employees’ 2012 Form W-2s.

Birth-control coverage—Nongrandfathered health insurance plans must cover women’s preventive services, including contraception, without charging a copayment, coinsurance or a deductible.


Employer mandate—Employers with 50 or more employees that do not offer health coverage and that have one full-time employee receiving a subsidy will pay a penalty of $2,000 for each full-time employee, after the first 30 employees. And those that do offer health coverage and have one full-time employee opting out and receive a federal subsidy to purchase insurance on a state exchange will also pay a penalty of $2,000 per employee.

Grandfathered plans—Waiting periods longer than 90 days for health coverage are prohibited. Employers may offer wellness program incentives/penalties of up to 30 percent of premiums to employees.

State health insurance exchanges—States must create exchanges to help small employers provide health plan coverage to their employees.

Individual mandate—Individuals must purchase health insurance. Any employee who earns up to four times the federal poverty level and pays more than 8 percent of their income for the employer-sponsored coverage can buy health insurance through health care exchanges.

Auto enrollment—Employers with 200 or more employees must automatically enroll newly hired or newly eligible full-time employees into a default health plan that provides “affordable” coverage. However, implementation of this provision has been delayed until the various government agencies issue regulations, which is not expected to happen before 2014.

Employee federal premium subsidies—Large employers that offer health coverage to full-time employees and their dependents are subject to a penalty if at least one full-time employee receives a federal subsidy because the employer-sponsored coverage is unaffordable.

Minimum values—Employers with 200 or more employees must automatically enroll newly hired or newly eligible full-time employees into an affordable default health plan.


State exchanges—States may begin to allow large employers to provide coverage through an exchange plan.


“Cadillac” tax—Employers must pay a 40 percent excise tax on health plans that exceed $10,200 for single coverage and $27,500 for family coverage.

SOURCE: Society for Human Resource Management

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