Change is constant as employers and employees navigate through the twists and turns of health benefits coverage. This infographic provides and overview of health care reform compliance deadlines.

1. 2014
Individuals must buy
health coverage or
pay a tax (starts at the
greater of $95 per
person or 1% of
household
income)
2014
Wellness rewards
increased to 30% of the
cost of coverage and up to
50% for tobacco - related
rewards; New rules for
reasonable alternative
standards
Jan. 1*
2014
Medicaid expanded in some states;
Small group insurance market reforms
(guaranteed issue & renewability); No limits
on pre-existing conditions expanded to cover
adults; No annual limits on Essential Health Benefits;
Non-grandfathered plans cover routine costs
of clinical trials for treatment of cancer or other
life-threatening diseases/conditions
Jan. 1
2014
Employers provide
enrollment count to
HHS to process annual
Transitional Reinsurance
Program (TRP) fee
($63/member for
2014)***
Nov. 15
(HHS will invoice
in Dec.)
2016
Employers
begin to comply
with IRC
§ 6055/6056
reporting
requirements
Jan. 1
2017
Employers with
>100 employees
can purchase
coverage through
health insurance
marketplace
Jan. 1
2018
40% excise tax
applies to
excess
coverage
provided by
"Cadillac Plans"
Jan. 1
20??
Uncertain
effective date for
non-discrimination
rules for insured plans
and auto enrollment
in large employer-
sponsored group
health plans
Non-grandfathered
plans must limit out-of-
pocket expenses to no more
than the HDHP statutory
maximums for the first plan
year on or after 1/1/2014;
transition relief available
for plans using
different medical/
Rx providers
2015
Health Care
FSA may provide
$500 carryover
feature
Jan. 1
2014
No eligibility
waiting period
longer than
90 days
Plan years starting on
or after
1/1/2014
2014
Measure hours
to determine if
“Applicable Large
Employer”in 2015
(use any consecutive
6-month period in 2014)
Jan. 1
2014
Non-grandfathered
plans cover breast
cancer-reducing
Rx with no
cost-sharing
Plan years starting
on or after 9/24/14
2014
Large HIPAA
Covered Entities
register for
Health Plan ID
number
Nov. 5**
2014
ACA reporting
optional; use 2014 to
assess readiness to
comply with
reporting
requirements
Jan. 1- Dec. 31
2015
Pay 1st
installment of
2014 TRP fee
($52.50/
member)
Jan - within 30
days of HHS
invoice
2015
Penalties under
Employer Shared
Responsibility rules
take effect for
employers with > 100
Full-Time Equivalent
employees (FTEs)
Jan. 1
2015
HHS will invoice
2nd installment of
2014 TRP fee
($10.50/member)
December
(Due in 30 days)
2015
HIPAA Covered
Entity obtains CAQH
CORE certification from
authorized testing
vendor
Jan. 1- Dec. 31**
2016
Penalties under
Employer Shared
Responsibility Rules take
effect for employers
with 50-99 FTEs
Jan. 1
2016
Employers with >
50 FTEs provide
minimum essential
coverage to at least
95% of FTEs
(Up from 70%)
Jan. 1
ststana dards
WELLNESS
PROGRAMS
HEALTH
INSURANCE
EXCHANGES
EMPLOYER
HEALTH
BENEFITS
Health Care Reform Path to Compliance
For assistance on your compliance journey contact Bruce Davis, principal, 419.327.4133, bdavis@findleydavies.com.
The Preceding is a summary and reflects our general understanding of applicable changes in the law that may require actions by an employer and the effective dates for those
changes listed or described. This is merely a summary and should not be relied on exclusively to determine your actions with respect to your health care benefit plans or
programs and compliance with the law. You should discuss your situation with your consultant, accountant and/or attorney to determine what is best for your situation.
© Findely Davies, Inc.
All rights reserved
2015
Non-grandfathered plans
must combine Medical/Rx
for application of the out -
of-pocket maximum limit;
plans may split the
maximum as long as the
combination does not
exceed the out-of-
pocket maximum
Jan. 1
2014
One thing’s certain, change is constant as employers and employees navigate
through the twists and turns of health benefits coverage.
Path last revised on 7/8/2015
* April 2015 EEOC regulations re: ADA and wellness plans
** Effective Oct. 31, 2014 enforcement delay
***$44/member for 2015 and $27/member for 2016
2016
Non-grandfathered plans must embed a
feature for Family coverage so that no one
individual pays more than the statutory
self-only OPM maximum of $6,850
Jan. 1