• Healthcare Reform Timeline

  • 2010

    • Adult child coverage until age 26
    • Annual dollar limits restricted
    • Early retiree reinsurance program (ERRP)
    • Emergency room coverage as in-network, no prior authorization
    • Initial appeals review standards
    • Lifetime dollar limits prohibited
    • Medicare Part D rebate for beneficiaries in the gap
    • No pre-existing conditions for children up to age 19
    • Online consumer information at healthcare.gov
    • Pediatricians as primary care physicians (PCPs), direct access to OB/GYNs
    • Preventive services with no cost sharing
    • Rescissions prohibited except for fraud or nonpayment
    • Small business tax credit
    • Temporary high-risk pool

    2011

    • Annual fee on pharmaceutical manufacturers begins
    • Annual rate review process
    • Appeals ombudsmen and process documentation
    • Auto-enrollment for groups with 200+ full time employees (implementation delayed until regulations released)
    • Discounts in Medicare Part D “donut hole”
    • Health savings, health reiumbursement and flexible spending accounts (HSA, HRA, FSA): limitations for over-the counter medications
    • Increase penalty for non-qualified HSA withdrawals
    • Minimum medical loss ratio (MLR): 85% for large group; 80% for small group and individual
    • Non-discrimination rules apply to insured plans (implementation delayed until regulations are released)
    • Small business wellness grants (implementation delayed until regulations are released

    2012

    • 60-day advance notice of material modifications
    • Accountable Care Organization requirements
    • Appeals provision fully implemented
    • First medical loss ratio rebates to be paid by August
    • New women’s preventive services with no cost sharing
    • Patient-centered Outcomes Research Institute (PCORI) fee ($1per member/year)
    • Quality bonus begins for Medicare Advantage plans
    • Quality of care reporting requirements (implementation delayed until regulations are released)
    • Summary of benefits and coverage (SBC) and the Uniform Glossary

    2013

    • Administrative simplification begins
    • Annual fee on medical device sales begins
    • Deduction for expenses allocable to the Part D subsidy for “qualified prescription drug plans”eliminated
    • Employee notification of access to Exchanges
    • Flexibile spending account (FSA) contributions limited to $2,500
    • High earner tax begins (applies to individuals)
    • Patient-centered Outcomes Research Institute (PCORI) fee increases to $2 per member/year
    • W-2 reporting of the value of employer-sponsored health benefits

    2014

    • Coverage for all adult children until age 26 including those that have employer coverage (formerly not covered for grandfathered plans)
    • Deductible caps cannot exceed $2,000 for individual and $4,000 for family
    • Essential health benefits required for small employers
    • Guaranteed issue and renewability
    • Health Benefit Exchanges
    • ICD-10 code adoption
    • Individual mandate
    • Insurer fee – permanent
    • Mandatory coverage for clinical trials
    • No annual dollar limits
    • No pre-existing condition exclusions
    • Out-of-pocket limits (OOP) must comply with OOP limits for health savings account (HSA) qualified plans
    • Rating restrictions / Adjusted community rating
    • Tax credits and subsidies for individuals and small employers
    • Transitional reinsurance fee (2014-2016)
    • Waiting period limits
    • Wellness programs

    2015 and beyond

    • Employer mandate - must offer health coverage to 70% of their full-time employees:
      • Employers with 100 or more employees (2015)
      • Employers with 50-99 employees (2016)
       
    • Employers must offer health coverage to at least 95% of their full-time employees (2016)
    • High-value plan excise tax begins (2018)
    • Medicare Part D “donut hole” closed by 2020
    • States can open Exchange to CHIP eligibles (2015) and all employers (2017)