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Requirements and Applicability
Apply to     Apply to     Apply to
                                                                           Apply to    Apply to   Apply to
                                     Large         Small     Very Small                                      Additional
                                                                             Fully      Self-      Grand-
  Requirement     Effective Date   Employers    Employers    Employers                                       Guidance        Action Needed         Comments            Penalties
                                                                           Insured     Funded     fathered
                                     (>100       (50 - 100      (<50                                          Needed
                                                                            Plans       Plans       Plans
                                   employees)   employees)   employees)
                                                                                                                          If receive rebate,
                                                                                                                          must share
                                                                                                                          prorata with          Precise method
                                                                                                                          participants; if no   of determining
                                                                                                                          rebate received,      each               Failure to
Minimum                                                                                                                   for first year of     participant's      distribute
Medical Loss                                                                                                              rebate only,          share of rebate    appropriately
                  7/12/2012        Yes          Yes          Yes          Yes         No          Yes        No
Ratio (MLR)                                                                                                               include notice        is not             may be a
Rebates                                                                                                                   with first plan       prescribed;        prohibited
                                                                                                                          materials (e.g.       must use           transaction
                                                                                                                          open enrollment       "reasonable"
                                                                                                                          materials)            approach
                                                                                                                          provided after
                                                                                                                          7/1/12

                                                                                                                                                Insurer will
                                                                                                                                                provide for
                                                                                                                                                insured
                  First open
                                                                                                                                                coverage and
Summary of        enrollment                                                                                              Prepare SBC and
                                                                                                                                                TPA likely will    $1,000/ failure
Benefits          or plan year     Yes          Yes          Yes          Yes         Yes         Yes        No           distribute by due
                                                                                                                                                help with self-    to provide
Coverage          after                                                                                                   date
                                                                                                                                                funded, but
                  9/23/2012
                                                                                                                                                plan sponsor
                                                                                                                                                ultimately
                                                                                                                                                responsible


                                                                                                                          Update
Maximum                                                                                                                   enrollment
                                                                                                                                                This is a longer   Plan disqualifi-
Health FSA        First day of                                                                                            materials, verify
                                                                                                                                                time to amend      cation (all
Contribution of   2013 plan        Yes          Yes          Yes          Yes         Yes         Yes        No           administration is
                                                                                                                                                than is usually    benefits become
$2,500            year                                                                                                    updated, amend
                                                                                                                                                given              taxable)
(indexed)                                                                                                                 plan by
                                                                                                                          12/31/2014
Apply to      Apply to     Apply to
                                                                              Apply to    Apply to   Apply to
                                       Large          Small     Very Small                                      Additional
                                                                                Fully      Self-      Grand-
   Requirement      Effective Date   Employers     Employers    Employers                                       Guidance        Action Needed        Comments           Penalties
                                                                              Insured     Funded     fathered
                                       (>100        (50 - 100      (<50                                          Needed
                                                                               Plans       Plans       Plans
                                     employees)    employees)   employees)
                                                                                                                             Ensure W-2
                                                                                                                             system has           Report total
W-2 Reporting                        Yes, if
                                                                                                                             needed data on       value
of Value of                          issued
                    1/31/2013                      No           No           Yes         Yes         Yes        No           value of GHP         (employer +       Likely $50/ W-2
Group Health                         >250 W-
                                                                                                                             coverage and can     employee
Benefit                              2's in 2011
                                                                                                                             correctly populate   contributions)
                                                                                                                             Box 12
                                                                                                                                                  Employee owes
                                                                                                                                                  an additional
                                                                                                                                                  0.9% Medicare
                                                                                                                                                  withholding if
                                                                                                                             Update pay           filing married
Additional FICA                                                                                                              withholding to       with combined
withholding on                                                                                                               collect additional   wages             Likely 20% of
employee's          1/1/2013         Yes           Yes          Yes          Yes         Yes         Yes        Yes          0.9% FICA for        >$250,000 or      amount under-
share of wages                                                                                                               employees            filing single     withheld
> $200,000                                                                                                                   earning >            with wages >
                                                                                                                             $200,000             $200,000.
                                                                                                                                                  Employer
                                                                                                                                                  responsibility
                                                                                                                                                  limited as
                                                                                                                                                  described
                                                                                                                                                  Only affects
                                                                                                                                                  employers
                                                                                                                                                  receiving
                                                                                                                                                  subsidy for
Loss of             First day of                                                                                             Consider subsidy
                                                                                                                                                  providing Rx to
Deductibility for   2013 tax         Yes           Yes          Yes          Yes         Yes         Yes        No           taxable income for
                                                                                                                                                  retirees;
Part D subsidy      year                                                                                                     2013 and later
                                                                                                                                                  change also
                                                                                                                                                  likely impacts
                                                                                                                                                  financial
                                                                                                                                                  reporting
Apply to
                                  Apply to     Apply to
                                                            Very Small    Apply to    Apply to   Apply to
                                   Large         Small                                                      Additional
                                                            Employers       Fully      Self-      Grand-
  Requirement   Effective Date   Employers    Employers                                                     Guidance        Action Needed         Comments       Penalties
                                                               (<50       Insured     Funded     fathered
                                   (>100       (50 - 100                                                     Needed
                                                            employees      Plans       Plans       Plans
                                 employees)   employees)
                                                                 )
                                                                                                                                               Exchange
                                                                                                                         Create and send       contact details
Notice of                                                                                                                notices re            are not
                3/1/2013         Yes          Yes           Yes          Yes         Yes         Yes        Yes
Exchanges                                                                                                                availability of       available yet;
                                                                                                                         exchanges             model notices
                                                                                                                                               are expected
                                                                                                                                               Fee increases
                                                                                                                                               to $2/covered
                                                                                                                                               life for
                                                                                                                                               following year,
                                                                                                                                               then $2
                                                                                                                                               (indexed)/
                                                                                                                                               covered life;
                                                                                                                                               fee applies to
                                                                                                                         Calculate fee
                                                                                                                                               plan/ policy
                                                                                                                         ($1/covered life)
Patient         7/31/2013                                                                                                                      years ending
                                                                                                                         and pay on IRS
Centered        for plan                                                                                                                       after
                                                                                                                         Form 720 if self-
Outcomes/       years                                                                                                                          9/30/2012
                                 Yes          Yes           Yes          Yes         Yes         Yes        Yes          funded; insurer
Comparative     ending                                                                                                                         through
                                                                                                                         calculates and
Effectiveness   10/1/12 -                                                                                                                      plan/policy
                                                                                                                         pays for insured
Fee Due         12/31/12                                                                                                                       years ending
                                                                                                                         plans but likely
                                                                                                                                               on or before
                                                                                                                         will pass fee along
                                                                                                                                               9/30/2019; fee
                                                                                                                                               is due by 7/31
                                                                                                                                               of the calendar
                                                                                                                                               following the
                                                                                                                                               plan year;
                                                                                                                                               applies to
                                                                                                                                               retiree only
                                                                                                                                               plans
                                              Yes (unless
Open                                          state has                                                                  If eligible, decide
enrollment                                    chosen a                                                                   whether to
                10/1/2013        No                         Yes          Yes         No          Yes        Yes
begins for                                    50-                                                                        participate in
exchanges                                     employee                                                                   exchange/SHOP
                                              threshold
Apply to
                                     Apply to     Apply to
                                                              Very Small    Apply to    Apply to    Apply to
                                      Large         Small                                                      Additional
                                                              Employers       Fully      Self-       Grand-
  Requirement      Effective Date   Employers    Employers                                                     Guidance        Action Needed          Comments              Penalties
                                                                 (<50       Insured     Funded      fathered
                                      (>100       (50 - 100                                                     Needed
                                                              employees      Plans       Plans        Plans
                                    employees)   employees)
                                                                   )

                                                                                                                                                   Guidance was
Report to HHS
                                                                                                                                                   due prior to
and participants                                                                                                            Report as required                         HHS will
                   TBD              Yes          Yes          Yes          Yes         Yes         No          Yes                                 3/23/12, but
on quality of                                                                                                               once rules set                             determine
                                                                                                                                                   none has been
care
                                                                                                                                                   issued yet




                                                                                                                                                                       $100/ discrimin-
                   TBD for                                                                                                                                             ated-against
                                                                                                                            Determine
                   insured                                                                                                                                             employee if
                                                                                                   No if                    whether meet
                   plans;                                                                                                                                              insured; loss of
Nondiscrimin-                                                                                      insured,                 discrimination
                   existing                                                                                                                                            tax preference
ation                               Yes          Yes          Yes          Yes         Yes         yes if      Yes          requirements and
                   requiremen                                                                                                                                          for unduly
requirements                                                                                       self-                    make needed
                   t for self-                                                                                                                                         benefited highly
                                                                                                   funded                   adjustments if do
                   funded                                                                                                                                              compensated
                                                                                                                            not
                   plans                                                                                                                                               individual if self-
                                                                                                                                                                       funded




                                                                                                                            Auto-enroll
                                                                                                                            employees who do       Unclear if will
                                                                                                                            not affirmatively      use same
Automatic          2014 or          Yes (if >                                                                               enroll in or decline   definition of
                                                 No           No           Yes         Yes         Yes         Yes
enrollment         later            200 EEs)                                                                                coverage, most         employee as
                                                                                                                            likely in lowest       will for "play or
                                                                                                                            cost plan, once        pay"
                                                                                                                            rules are set
Apply to
                                      Apply to      Apply to
                                                                 Very Small    Apply to    Apply to   Apply to
                                       Large          Small                                                      Additional
                                                                 Employers       Fully      Self-      Grand-
  Requirement       Effective Date   Employers     Employers                                                     Guidance        Action Needed           Comments           Penalties
                                                                    (<50       Insured     Funded     fathered
                                       (>100        (50 - 100                                                     Needed
                                                                 employees      Plans       Plans       Plans
                                     employees)    employees)
                                                                      )
                                                                                                                                                                        If no coverage is
                                                                                                                                                      Employer to
                                                                                                                                                                        offered, penalty
                                                                                                                                                      pay a penalty
                                                                                                                                                                        is # of FT EEs -
                                                                                                                                                      for each FT
                                                                                                                                                                        30 EEs x
                                                                                                                                                      (30+
                                                                                                                                                                        $166.67/ mo; if
                                                                                                                                                      hours/week) EE
                                                                                                                                                                        coverage is
                                                                                                                              Begin to consider       who is not
                                                                                                                                                                        offered but it's
Employer                                                                                                                      whether to play or      offered
                                                                                                                                                                        unaffordable or
shared                                                                                                                        pay (i.e., offer        coverage that
                    1/1/2014         Yes          Yes            No           Yes         Yes         Yes        Yes                                                    below minimum
responsibility                                                                                                                compliant               meets
                                                                                                                                                                        essential,
("play or pay")                                                                                                               coverage or pay         minimum
                                                                                                                                                                        penalty is
                                                                                                                              the penalty)            essential (60%)
                                                                                                                                                                        $250/mo. for
                                                                                                                                                      level & is
                                                                                                                                                                        each FT EE who
                                                                                                                                                      affordable
                                                                                                                                                                        gets a premium
                                                                                                                                                      (<9.5% of
                                                                                                                                                                        credit or cost
                                                                                                                                                      household
                                                                                                                                                                        share through
                                                                                                                                                      income)
                                                                                                                                                                        an exchange
                                     Not
                                                  Yes (unless
                                     available                                                                                If eligible, begin to   Exchanges/
                                                  state
                                     until at                                                                                 consider whether        SHOP will
                                                  restricts to
Exchanges/                           least                                                                                    to provide              provide online
                    1/1/2014                      employers      Yes          Yes         No          Yes        Yes
SHOP                                 2017;                                                                                    coverage inside or      resource to
                                                  with 50 or
                                     state by                                                                                 outside of              elect health
                                                  fewer
                                     state                                                                                    exchange/SHOP           coverage
                                                  lives)
                                     decision
Elimination of                                                                                                                Determine if
Annual Dollar       First day of                                                                                              current plan                              Up to $100/
Limits on           2014 plan        Yes          Yes            Yes          Yes         Yes         Yes        Yes          design complies; if                       affected
Essential           year                                                                                                      not, revise                               participant/ day
Benefits                                                                                                                      plan/policy
Elimination of                                                                                                                Determine if
Pre-Ex Limits for   First day of                                                                                              current plan                              Up to $100/
adults (as well     2014 plan        Yes          Yes            Yes          Yes         Yes         Yes        No           design complies; if                       affected
as children         year                                                                                                      not, revise                               participant/ day
under age 19)                                                                                                                 plan/policy
Apply to
                                    Apply to     Apply to
                                                             Very Small    Apply to    Apply to   Apply to
                                     Large         Small                                                     Additional
                                                             Employers       Fully      Self-      Grand-
   Requirement    Effective Date   Employers    Employers                                                    Guidance        Action Needed         Comments            Penalties
                                                                (<50       Insured     Funded     fathered
                                     (>100       (50 - 100                                                    Needed
                                                             employees      Plans       Plans       Plans
                                   employees)   employees)
                                                                  )
                                                                                                                                                Agencies have
                                                                                                                                                not yet
                                                                                                                                                determined if
                                                                                                                          Determine if          first of month
Waiting period    First day of                                                                                                                                     Up to $100/
                                                                                                                          current eligibility   after 90 days is
cannot exceed     2014 plan        Yes          Yes          Yes          Yes         Yes         Yes        Yes                                                   affected
                                                                                                                          rules comply; if      permissible,
90 days           year                                                                                                                                             participant/ day
                                                                                                                          not, revise           how to address
                                                                                                                                                those who
                                                                                                                                                move between
                                                                                                                                                PT and FT, etc.
                                                                                                                          Determine if
No                                                                                                                                              Minimal
                  First day of                                                                                            current plan                             Up to $100/
discrimination                                                                                                                                  change from
                  2014 plan        Yes          Yes          Yes          Yes         Yes         No         Yes          design complies; if                      affected
based on health                                                                                                                                 current HIPAA
                  year                                                                                                    not, revise                              participant/ day
status                                                                                                                                          rules
                                                                                                                          plan/policy
                                                                                                                                                Maximum
                                                                                                                                                deductible of
                                                                                                                          Determine if
                                                                                                                                                $2,000 for
Limits on cost-   First day of                                                                                            current plan                             Up to $100/
                                                                                                                                                single and
sharing and       2014 plan        Yes          Yes          Yes          Yes         Yes         No         Yes          design complies; if                      affected
                                                                                                                                                $4,000 family;
deductibles       year                                                                                                    not, revise                              participant/ day
                                                                                                                                                maximum OOP
                                                                                                                          plan/policy
                                                                                                                                                based on HDHP
                                                                                                                                                limits
                                                                                                                          Determine if
Mandated          First day of                                                                                            current plan                             Up to $100/
coverage of       2014 plan        Yes          Yes          Yes          Yes         Yes         No         Yes          design complies; if                      affected
clinical trials   year                                                                                                    not, revise                              participant/ day
                                                                                                                          plan/policy
Apply to
                                     Apply to     Apply to
                                                              Very Small    Apply to    Apply to   Apply to
                                      Large         Small                                                     Additional
                                                              Employers       Fully      Self-      Grand-
  Requirement      Effective Date   Employers    Employers                                                    Guidance        Action Needed        Comments               Penalties
                                                                 (<50       Insured     Funded     fathered
                                      (>100       (50 - 100                                                    Needed
                                                              employees      Plans       Plans       Plans
                                    employees)   employees)
                                                                   )
                                                                                                                                                Agencies have
                                                                                                                                                authority to
                                                                                                                                                increase
                                                                                                                           If have              permissible
                                                                                                                           HIPAA/PPACA-         reward to 50%
                                                                                                                           compliant            of cost of
                   First day of
Wellness                                                                                                                   wellness program,    coverage;
                   2014 plan        Yes          Yes          Yes          Yes         Yes         N/A        Yes                                                   N/A
Incentives                                                                                                                 may increase         compliance
                   year
                                                                                                                           incentive to 30%     with
                                                                                                                           of cost of single    HIPAA/PPACA
                                                                                                                           coverage             does not
                                                                                                                                                guarantee
                                                                                                                                                compliance
                                                                                                                                                with ADA
                                                                                                                                                These are the
                                                                                                                                                10 listed
                                                                                       Only for    Only for
                                    Only for                               Yes                                             If this applies,     categories of
                   First day of                                                        lifetime    lifetime
Essential health                    lifetime &                             (varies                                         determine if         benefits; this is
                   2014 plan                     Yes          Yes                      & annual    & annual   Yes
benefits applies                    annual                                 by group                                        offered coverage     not the same
                   year                                                                maximu      maximu
                                    max.                                   size)                                           is adequate          as "minimum
                                                                                       ms          ms
                                                                                                                                                essential
                                                                                                                                                benefits"
                                                                                                                                                Begins with
                                                                                                                                                coverage
Report to IRS                                                                                                                                   provided on or
and participants                                                                                                                                after 1/1/14;
                                                                                                                           Report as required                       Likely $50/
on minimum         1/31/2015        Yes          Yes          Yes          Yes         Yes         Yes        Yes                               insurers likely
                                                                                                                           once rules set                           employee
essential                                                                                                                                       to be
coverage                                                                                                                                        responsible for
                                                                                                                                                reporting for
                                                                                                                                                insured plans
Apply to
                                     Apply to     Apply to
                                                              Very Small    Apply to    Apply to   Apply to
                                      Large         Small                                                     Additional
                                                              Employers       Fully      Self-      Grand-
  Requirement      Effective Date   Employers    Employers                                                    Guidance        Action Needed        Comments          Penalties
                                                                 (<50       Insured     Funded     fathered
                                      (>100       (50 - 100                                                    Needed
                                                              employees      Plans       Plans       Plans
                                    employees)   employees)
                                                                   )
                                                                                                                                                Begins with
                                                                                                                                                coverage
                                                                                                                                                provided on or
                                                                                                                                                after 1/1/14;
Report to IRS
                                                                                                                                                IRS has
and participants
                                                                                                                           Report as required   requested
on coverage        1/31/2015        Yes          Yes          No           Yes         Yes         Yes        Yes
                                                                                                                           once rules set       comments on
offered by large
                                                                                                                                                combining
employers
                                                                                                                                                minimum
                                                                                                                                                essential and
                                                                                                                                                large employer
                                                                                                                                                reporting
                                                                                                                                                Employer pays
                                                                                                                                                excise tax if
                                                                                                                                                total cost of
                                                                                                                                                medical
                                                                                                                                                benefits (EE
                                                                                                                                                and ER
                                                                                                                           Determine if         contributions
                                                                                                                           current design       combined)
                                                                                                                                                                 40% non-
Excise tax on                                                                                                              falls below          exceeds
                   1/1/2018         Yes          Yes          Yes          Yes         Yes         Yes        Yes                                                deductible
high cost plans                                                                                                            threshold; if not,   $10,200
                                                                                                                                                                 excise tax
                                                                                                                           consider design      (single) or
                                                                                                                           changes              $27,500
                                                                                                                                                (family)
                                                                                                                                                [indexed]for
                                                                                                                                                medical, HRA
                                                                                                                                                and Section
                                                                                                                                                125 (pre-tax &
                                                                                                                                                health FSA)
ALREADY IN EFFECT
                                                                Apply to
                                      Apply to     Apply to
                                                               Very Small    Apply to    Apply to    Apply to
                                       Large         Small                                                      Additional
                                                               Employers       Fully      Self-       Grand-
  Requirement       Effective Date   Employers    Employers                                                     Guidance        Action Needed       Comments            Penalties
                                                                  (<50       Insured     Funded      fathered
                                       (>100       (50 - 100                                                     Needed
                                                               employees      Plans       Plans        Plans
                                     employees)   employees)
                                                                    )
                                                                                                                                                 In 2014,
                                                                                                                                                 grandfathered
                                                                                                                                                 plans must
                                                                                                                             Verify plan/SPD     cover
Cover               First day of                                                                                             has been            dependent          Up to $100/
dependent to        2011 plan        Yes          Yes          Yes          Yes         Yes         Partly      No           amended and         even if            affected
age 26              year                                                                                                     administration is   dependent has      participant/ day
                                                                                                                             correct             employer-
                                                                                                                                                 provided
                                                                                                                                                 coverage
                                                                                                                                                 available
                                                                                                                             Verify plan/SPD
Elimination of      First day of                                                                                             has been                               Up to $100/
Lifetime Dollar     2011 plan        Yes          Yes          Yes          Yes         Yes         Yes         No           amended and                            affected
Limit               year                                                                                                     administration is                      participant/ day
                                                                                                                             correct
Restriction on                                                                                                               Verify plan/SPD
Annual Dollar       First day of                                                                                             has been                               Up to $100/
Limits on           2011 plan        Yes          Yes          Yes          Yes         Yes         Yes         No           amended and                            affected
Essential           year                                                                                                     administration is                      participant/ day
Benefits                                                                                                                     correct
                                                                                                                             Verify plan/SPD
Elimination of
                    First day of                                                                                             has been                               Up to $100/
Pre-Ex Limits for
                    2011 plan        Yes          Yes          Yes          Yes         Yes         Yes         No           amended and                            affected
children under
                    year                                                                                                     administration is                      participant/ day
age 19
                                                                                                                             correct
                                                                                                                                                 Generally may
                                                                                                                                                 not terminate
                    First day of                                                                                             Verify              ineligible         Up to $100/
Limits on
                    2011 plan        Yes          Yes          Yes          Yes         Yes         Yes         No           administration is   covered            affected
Rescissions
                    year                                                                                                     correct             persons retro      participant/ day
                                                                                                                                                 to ineligibility
                                                                                                                                                 date
Apply to
                                     Apply to     Apply to
                                                              Very Small    Apply to    Apply to   Apply to
                                      Large         Small                                                     Additional
                                                              Employers       Fully      Self-      Grand-
  Requirement      Effective Date   Employers    Employers                                                    Guidance        Action Needed        Comments            Penalties
                                                                 (<50       Insured     Funded     fathered
                                      (>100       (50 - 100                                                    Needed
                                                              employees      Plans       Plans       Plans
                                    employees)   employees)
                                                                   )
                                                                                                                                               HHS may
                                                                                                                           Verify plan/SPD     periodically
                                                                                                                                                                    Up to $100/
First dollar       First day of                                                                                            has been            revise definition
                                                                                                                                                                    affected
coverage for       2011 plan        Yes          Yes          Yes          Yes         Yes         No         No           amended and         of preventive
                                                                                                                                                                    participant/
Preventive Care    year                                                                                                    administration is   care, such as they
                                                                                                                                                                    day
                                                                                                                           correct             have done with
                                                                                                                                               women's care
                                                                                                                           Verify plan/SPD
                                                                                                                                                                    Up to $100/
                   First day of                                                                                            has been
Enhanced                                                                                                                                                            affected
                   2011 plan        Yes          Yes          Yes          Yes         Yes         No         Yes          amended and
Appeals Rules                                                                                                                                                       participant/
                   year                                                                                                    administration is
                                                                                                                                                                    day
                                                                                                                           correct
No                                                                                                                         Verify plan/SPD
reimbursement      First day of                                                                                            has been
                                                                                                                                               Applies to FSA's,
of OTC drugs       2011 plan        Yes          Yes          Yes          N/A         N/A         Yes        No           amended and
                                                                                                                                               HRA's and HSA's
w/o a              year                                                                                                    administration is
prescription                                                                                                               correct
                                                                                                                           Verify plan/SPD
                                                                                                                           has been
                                                                                                                                                                    Up to $100/
                   First day of                                                                                            amended,
Primary care                                                                                                                                                        affected
                   2011 plan        Yes          Yes          Yes          Yes         Yes         No         No           participants
physician choice                                                                                                                                                    participant/
                   year                                                                                                    advised and
                                                                                                                                                                    day
                                                                                                                           administration is
                                                                                                                           correct
                                                                                                                           Verify plan/SPD
                                                                                                                           has been
                                                                                                                                                                    Up to $100/
OON                First day of                                                                                            amended,
                                                                                                                                                                    affected
emergency care     2011 plan        Yes          Yes          Yes          Yes         Yes         No         No           participants
                                                                                                                                                                    participant/
coverage           year                                                                                                    advised and
                                                                                                                                                                    day
                                                                                                                           administration is
                                                                                                                           correct
Apply to
                                  Apply to     Apply to
                                                            Very Small   Apply to    Apply to   Apply to
                                   Large         Small                                                     Additional
                                                            Employers      Fully      Self-      Grand-
  Requirement   Effective Date   Employers    Employers                                                    Guidance      Action Needed       Comments   Penalties
                                                               (<50      Insured     Funded     fathered
                                   (>100       (50 - 100                                                    Needed
                                                            employees     Plans       Plans       Plans
                                 employees)   employees)
                                                                 )
Notes:

                                              Controlled
Under PPACA,
                                              group rules
cutoff for a
                                              generally                             "Fully
“small
                                              apply                                 insured"
employer" may
                                              when de-                              includes
be 50 or 100,
                                              termining                             HMO's
depending on
                                              employer
provision
                                              size




                        This chart reflects UBA's understanding of the available guidance as of the date shown and is subject to change.
                                      It is provided as general information and should not be considered legal or tax advice.




                                                                                                                    Damon H. Lee, Vice President
                                                                                                                        Horizon Agency, Inc.
                                                                                                                      6500 City West Parkway
                                                                                                                      Eden Prairie, MN 55344
                                                                                                                    damon@horizonagency.com
                                                                                                                           952-914-7187

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What employers need to know ppaca 9 26-12

  • 2. Apply to Apply to Apply to Apply to Apply to Apply to Large Small Very Small Additional Fully Self- Grand- Requirement Effective Date Employers Employers Employers Guidance Action Needed Comments Penalties Insured Funded fathered (>100 (50 - 100 (<50 Needed Plans Plans Plans employees) employees) employees) If receive rebate, must share prorata with Precise method participants; if no of determining rebate received, each Failure to Minimum for first year of participant's distribute Medical Loss rebate only, share of rebate appropriately 7/12/2012 Yes Yes Yes Yes No Yes No Ratio (MLR) include notice is not may be a Rebates with first plan prescribed; prohibited materials (e.g. must use transaction open enrollment "reasonable" materials) approach provided after 7/1/12 Insurer will provide for insured First open coverage and Summary of enrollment Prepare SBC and TPA likely will $1,000/ failure Benefits or plan year Yes Yes Yes Yes Yes Yes No distribute by due help with self- to provide Coverage after date funded, but 9/23/2012 plan sponsor ultimately responsible Update Maximum enrollment This is a longer Plan disqualifi- Health FSA First day of materials, verify time to amend cation (all Contribution of 2013 plan Yes Yes Yes Yes Yes Yes No administration is than is usually benefits become $2,500 year updated, amend given taxable) (indexed) plan by 12/31/2014
  • 3. Apply to Apply to Apply to Apply to Apply to Apply to Large Small Very Small Additional Fully Self- Grand- Requirement Effective Date Employers Employers Employers Guidance Action Needed Comments Penalties Insured Funded fathered (>100 (50 - 100 (<50 Needed Plans Plans Plans employees) employees) employees) Ensure W-2 system has Report total W-2 Reporting Yes, if needed data on value of Value of issued 1/31/2013 No No Yes Yes Yes No value of GHP (employer + Likely $50/ W-2 Group Health >250 W- coverage and can employee Benefit 2's in 2011 correctly populate contributions) Box 12 Employee owes an additional 0.9% Medicare withholding if Update pay filing married Additional FICA withholding to with combined withholding on collect additional wages Likely 20% of employee's 1/1/2013 Yes Yes Yes Yes Yes Yes Yes 0.9% FICA for >$250,000 or amount under- share of wages employees filing single withheld > $200,000 earning > with wages > $200,000 $200,000. Employer responsibility limited as described Only affects employers receiving subsidy for Loss of First day of Consider subsidy providing Rx to Deductibility for 2013 tax Yes Yes Yes Yes Yes Yes No taxable income for retirees; Part D subsidy year 2013 and later change also likely impacts financial reporting
  • 4. Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) Exchange Create and send contact details Notice of notices re are not 3/1/2013 Yes Yes Yes Yes Yes Yes Yes Exchanges availability of available yet; exchanges model notices are expected Fee increases to $2/covered life for following year, then $2 (indexed)/ covered life; fee applies to Calculate fee plan/ policy ($1/covered life) Patient 7/31/2013 years ending and pay on IRS Centered for plan after Form 720 if self- Outcomes/ years 9/30/2012 Yes Yes Yes Yes Yes Yes Yes funded; insurer Comparative ending through calculates and Effectiveness 10/1/12 - plan/policy pays for insured Fee Due 12/31/12 years ending plans but likely on or before will pass fee along 9/30/2019; fee is due by 7/31 of the calendar following the plan year; applies to retiree only plans Yes (unless Open state has If eligible, decide enrollment chosen a whether to 10/1/2013 No Yes Yes No Yes Yes begins for 50- participate in exchanges employee exchange/SHOP threshold
  • 5. Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) Guidance was Report to HHS due prior to and participants Report as required HHS will TBD Yes Yes Yes Yes Yes No Yes 3/23/12, but on quality of once rules set determine none has been care issued yet $100/ discrimin- TBD for ated-against Determine insured employee if No if whether meet plans; insured; loss of Nondiscrimin- insured, discrimination existing tax preference ation Yes Yes Yes Yes Yes yes if Yes requirements and requiremen for unduly requirements self- make needed t for self- benefited highly funded adjustments if do funded compensated not plans individual if self- funded Auto-enroll employees who do Unclear if will not affirmatively use same Automatic 2014 or Yes (if > enroll in or decline definition of No No Yes Yes Yes Yes enrollment later 200 EEs) coverage, most employee as likely in lowest will for "play or cost plan, once pay" rules are set
  • 6. Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) If no coverage is Employer to offered, penalty pay a penalty is # of FT EEs - for each FT 30 EEs x (30+ $166.67/ mo; if hours/week) EE coverage is Begin to consider who is not offered but it's Employer whether to play or offered unaffordable or shared pay (i.e., offer coverage that 1/1/2014 Yes Yes No Yes Yes Yes Yes below minimum responsibility compliant meets essential, ("play or pay") coverage or pay minimum penalty is the penalty) essential (60%) $250/mo. for level & is each FT EE who affordable gets a premium (<9.5% of credit or cost household share through income) an exchange Not Yes (unless available If eligible, begin to Exchanges/ state until at consider whether SHOP will restricts to Exchanges/ least to provide provide online 1/1/2014 employers Yes Yes No Yes Yes SHOP 2017; coverage inside or resource to with 50 or state by outside of elect health fewer state exchange/SHOP coverage lives) decision Elimination of Determine if Annual Dollar First day of current plan Up to $100/ Limits on 2014 plan Yes Yes Yes Yes Yes Yes Yes design complies; if affected Essential year not, revise participant/ day Benefits plan/policy Elimination of Determine if Pre-Ex Limits for First day of current plan Up to $100/ adults (as well 2014 plan Yes Yes Yes Yes Yes Yes No design complies; if affected as children year not, revise participant/ day under age 19) plan/policy
  • 7. Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) Agencies have not yet determined if Determine if first of month Waiting period First day of Up to $100/ current eligibility after 90 days is cannot exceed 2014 plan Yes Yes Yes Yes Yes Yes Yes affected rules comply; if permissible, 90 days year participant/ day not, revise how to address those who move between PT and FT, etc. Determine if No Minimal First day of current plan Up to $100/ discrimination change from 2014 plan Yes Yes Yes Yes Yes No Yes design complies; if affected based on health current HIPAA year not, revise participant/ day status rules plan/policy Maximum deductible of Determine if $2,000 for Limits on cost- First day of current plan Up to $100/ single and sharing and 2014 plan Yes Yes Yes Yes Yes No Yes design complies; if affected $4,000 family; deductibles year not, revise participant/ day maximum OOP plan/policy based on HDHP limits Determine if Mandated First day of current plan Up to $100/ coverage of 2014 plan Yes Yes Yes Yes Yes No Yes design complies; if affected clinical trials year not, revise participant/ day plan/policy
  • 8. Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) Agencies have authority to increase If have permissible HIPAA/PPACA- reward to 50% compliant of cost of First day of Wellness wellness program, coverage; 2014 plan Yes Yes Yes Yes Yes N/A Yes N/A Incentives may increase compliance year incentive to 30% with of cost of single HIPAA/PPACA coverage does not guarantee compliance with ADA These are the 10 listed Only for Only for Only for Yes If this applies, categories of First day of lifetime lifetime Essential health lifetime & (varies determine if benefits; this is 2014 plan Yes Yes & annual & annual Yes benefits applies annual by group offered coverage not the same year maximu maximu max. size) is adequate as "minimum ms ms essential benefits" Begins with coverage Report to IRS provided on or and participants after 1/1/14; Report as required Likely $50/ on minimum 1/31/2015 Yes Yes Yes Yes Yes Yes Yes insurers likely once rules set employee essential to be coverage responsible for reporting for insured plans
  • 9. Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) Begins with coverage provided on or after 1/1/14; Report to IRS IRS has and participants Report as required requested on coverage 1/31/2015 Yes Yes No Yes Yes Yes Yes once rules set comments on offered by large combining employers minimum essential and large employer reporting Employer pays excise tax if total cost of medical benefits (EE and ER Determine if contributions current design combined) 40% non- Excise tax on falls below exceeds 1/1/2018 Yes Yes Yes Yes Yes Yes Yes deductible high cost plans threshold; if not, $10,200 excise tax consider design (single) or changes $27,500 (family) [indexed]for medical, HRA and Section 125 (pre-tax & health FSA)
  • 10. ALREADY IN EFFECT Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) In 2014, grandfathered plans must Verify plan/SPD cover Cover First day of has been dependent Up to $100/ dependent to 2011 plan Yes Yes Yes Yes Yes Partly No amended and even if affected age 26 year administration is dependent has participant/ day correct employer- provided coverage available Verify plan/SPD Elimination of First day of has been Up to $100/ Lifetime Dollar 2011 plan Yes Yes Yes Yes Yes Yes No amended and affected Limit year administration is participant/ day correct Restriction on Verify plan/SPD Annual Dollar First day of has been Up to $100/ Limits on 2011 plan Yes Yes Yes Yes Yes Yes No amended and affected Essential year administration is participant/ day Benefits correct Verify plan/SPD Elimination of First day of has been Up to $100/ Pre-Ex Limits for 2011 plan Yes Yes Yes Yes Yes Yes No amended and affected children under year administration is participant/ day age 19 correct Generally may not terminate First day of Verify ineligible Up to $100/ Limits on 2011 plan Yes Yes Yes Yes Yes Yes No administration is covered affected Rescissions year correct persons retro participant/ day to ineligibility date
  • 11. Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) HHS may Verify plan/SPD periodically Up to $100/ First dollar First day of has been revise definition affected coverage for 2011 plan Yes Yes Yes Yes Yes No No amended and of preventive participant/ Preventive Care year administration is care, such as they day correct have done with women's care Verify plan/SPD Up to $100/ First day of has been Enhanced affected 2011 plan Yes Yes Yes Yes Yes No Yes amended and Appeals Rules participant/ year administration is day correct No Verify plan/SPD reimbursement First day of has been Applies to FSA's, of OTC drugs 2011 plan Yes Yes Yes N/A N/A Yes No amended and HRA's and HSA's w/o a year administration is prescription correct Verify plan/SPD has been Up to $100/ First day of amended, Primary care affected 2011 plan Yes Yes Yes Yes Yes No No participants physician choice participant/ year advised and day administration is correct Verify plan/SPD has been Up to $100/ OON First day of amended, affected emergency care 2011 plan Yes Yes Yes Yes Yes No No participants participant/ coverage year advised and day administration is correct
  • 12. Apply to Apply to Apply to Very Small Apply to Apply to Apply to Large Small Additional Employers Fully Self- Grand- Requirement Effective Date Employers Employers Guidance Action Needed Comments Penalties (<50 Insured Funded fathered (>100 (50 - 100 Needed employees Plans Plans Plans employees) employees) ) Notes: Controlled Under PPACA, group rules cutoff for a generally "Fully “small apply insured" employer" may when de- includes be 50 or 100, termining HMO's depending on employer provision size This chart reflects UBA's understanding of the available guidance as of the date shown and is subject to change. It is provided as general information and should not be considered legal or tax advice. Damon H. Lee, Vice President Horizon Agency, Inc. 6500 City West Parkway Eden Prairie, MN 55344 damon@horizonagency.com 952-914-7187