Health Care Reform Timeline–Significant Upcoming Action Items

Attorney Jennifer Keating outlines key dates in connection with health care reform.

August 31, 2012


  • Sept. 23, plan years beginning on or after – issuance of SBC to applicants and enrollees
  • Sept. 30, plan/policy years ending after – required insurer contribution of $1/life covered under each health insurance policy (insured and self-insured) to assist with research of the comparative effectiveness of various forms of medical treatment; fee increases to $2 in 2013 and is indexed thereafter until phased out by 2019


  • Jan. 1 – begin W-2 reporting of value of health care coverage for employee in 2012
  • Jan. 1 – commencement of $2,500 annual limit for health FSA deferrals; limitation amount indexed in future years
  • Jan. 1 – elimination of tax deduction for the portion of health care expenses that are reimbursed to the employer through Medicare Part D (applies to insured and self-insured health plans, regardless of grandfathered status)
  • Jan. 1 – beginning this tax year, FICA Medicare tax is increased from 1.45% to 2.35% for annual wages over $200,000 ($250,000 for married couples filing jointly)
  • Mar.1 – notice provided by plans to employees and new hires of the state exchanges to be established by all states in 2014 (applies to insured and self-insured health plans, regardless of grandfathered status)


  • Jan. 1(est.) – pending further guidance, employers with more than 200 full-time employees are required to automatically enroll new full-time employees in health plan, with option to opt-out (applies to insured and self-insured health plans, regardless of grandfathered status)
  • Jan. 1 – various plan design changes and benefit mandates, such as coverage of essential benefits for insured individuals and small group plans, no preexisting condition exclusions, and elimination of waiting periods of more than 90 days for group plans (including grandfathered plans)
  • Jan. 1 – employers must report whether they have offered minimum essential coverage to employees, or pay penalty
  • Jan. 1 – individual mandate to obtain minimum essential coverage, or pay penalty (which is scheduled to increase in 2015 and again in 2016)
  • Jan. 1 – establishment of state health insurance exchanges
  • Jan. 1 – small business tax credits increase to up to 50% of employer costs
  • Jan. 1 – wellness program incentive increases to 30%


  • Jan. 1 – annual employer reporting of provision of minimum essential coverage to employees


  • Jan. 1 – states may permit large employers to purchase coverage through health insurance exchanges


  • Jan. 1 – imposition of “Cadillac” tax on high-cost plans

DISCLAIMER: This material is intended to be informational and does not constitute legal advice regarding any specific information.