Updated Timeline of PPACA's Major Provisions From Jan. 1, 2014 Forward

2014
EFFECTIVE DATE	ACA PROVISION
Calendar years beginning after Dec. 31, 2013	Health Insurance Provider Fee The health care reform law imposes an annual, non-deductible fee on the health insurance sector, allocated across the industry according to market share. The fee does not apply to companies whose net premiums written are $25 million or less.
Delayed for one year, until 2015 Additional one-year delay may apply	Employer Coverage Requirements See 2015 section below. The employer mandate penalties and related reporting requirements have been delayed for one year, until 2015. Also, medium-sized applicable large employers may qualify for an additional delay, until 2016.
Jan. 1, 2014	Individual Coverage Mandates ACA requires most individuals to obtain acceptable health insurance coverage or pay a penalty. Individuals may be eligible for an exemption from the penalty if they cannot obtain affordable coverage.
	Individual Health Insurance Subsidies ACA makes federal subsidies available through the Exchanges, in the form of premium tax credits and cost-sharing reductions, for low-income individuals who are not eligible for or offered other acceptable coverage.
	Health Insurance Exchanges ACA calls for the creation of state-based competitive marketplaces, known as Affordable Health Insurance Exchanges (Exchanges), for individuals and small businesses to purchase private health insurance.
	Reinsurance Payments Health insurance issuers and third-party administrators (TPAs) will be required to make contributions based on a federal contribution rate established by HHS. States may collect additional contributions on top of the federal contribution rate.
Plan years beginning on or after Jan. 1, 2014	Employer Wellness Programs Under health care reform, the potential incentive for employer wellness programs increases to 30 percent of the premium for employee participation in the program or meeting certain health standards. Employers must offer an alternative standard for those employees whom it is unreasonably difficult or inadvisable to meet the standard. Following a governmental study on wellness programs, the incentive may be increased to as much as 50 percent.
	Annual Limits Prohibited                                                                   Plans and issuers may not impose annual limits on the coverage of essential health benefits.
	Guaranteed Issue and Renewability Health insurance issuers offering health insurance coverage in the individual or group market in a state must accept every employer and individual in the state that applies for coverage and must renew or continue to enforce the coverage at the option of the plan sponsor or the individual. Grandfathered plans are exempt from this requirement.
	Pre-existing Condition Prohibition Group health plans and health insurance issuers may not impose pre-existing condition exclusions on coverage for anyone.
Plan years beginning on or after Jan. 1, 2014 (continued)	Nondiscrimination Based on Health Status Group health plans and health insurance issuers offering group or individual health insurance coverage (except grandfathered plans) may not establish rules for eligibility or continued eligibility based on health status-related factors.
	Nondiscrimination in Health Care Group health plans and health insurance issuers offering group or individual insurance coverage may not discriminate against any provider operating within their scope of practice. However, this provision does not require a plan to contract with any willing provider or prevent tiered networks. It also does not apply to grandfathered plans. Plans and issuers also may not discriminate against individuals based on whether they receive subsidies or cooperate in a Fair Labor Standards Act investigation.
	Insurance Premium Restrictions Health insurance issuers in the individual and small group markets will not be permitted to charge higher rates due to health status, gender or other factors. Premiums will be able to vary based only on age, geography, family size and tobacco use. The rating limitations will not apply to health insurance issuers that offer coverage in the large group market unless the state elects to offer large group coverage through the state exchange. Also, these restrictions do not apply to grandfathered coverage.
	Excessive Waiting Periods Prohibited Group health plans and health insurance issuers offering group or individual health insurance coverage will not be able to require a waiting period of more than 90 days.
	Coverage for Clinical Trial Participants Non-grandfathered group health plans and insurance policies will not be able to terminate coverage because an individual chooses to participate in a clinical trial for cancer or other life-threatening diseases or deny coverage for routine care that they would otherwise provide just because an individual is enrolled in such a clinical trial.
	Comprehensive Benefits Coverage Health insurance issuers that offer health insurance coverage in the individual or small group market will be required to provide the essential benefits package required of plans sold in the health insurance exchanges. This requirement does not apply to grandfathered plans.
	Limits on Cost-sharing Non-grandfathered group health plans will be subject to limits on cost-sharing or out-of-pocket costs. ACA’s annual deductible limit applies only to insured health plans offered in the small group market, whereas ACA’s out-of-pocket maximum limit applies to all non-grandfathered health plans.
Delayed for one year, until 2015	Reporting of Health Insurance Coverage See 2015 section below. The employer mandate penalties and related reporting requirements have been delayed for one year, until 2015.
Taxable years beginning in 2014	Small Business Health Care Tax Credit The second phase of the small business tax credit for qualified small employers will be implemented in 2014. These employers can receive a credit for contributions to purchase health insurance for employees, up to 50 percent of premiums.
After 2014 (delayed)	Automatic Enrollment ACA requires employers with more than 200 full-time employees that offer health coverage to automatically enroll new employees (and re-enroll current employees) in one of the employer’s health plans, subject to any permissible waiting period. Employers will not be required to comply with the automatic enrollment requirements until final regulations are issued and a final effective date is specified.

2015
EFFECTIVE DATE	ACA PROVISION
Jan. 1, 2015	Employer Coverage Requirements Employers with 50 or more employees will be subject to penalties if they do not provide health coverage to full-time employees, or if the coverage they provide is not affordable or does not provide minimum value. A full-time employee is an employee who was employed on average at least 30 hours of service per week. The employer mandate penalties and related reporting requirements have been delayed for one year, until 2015. Therefore, these payments will not apply for 2014. No other provisions of the ACA are affected by the delay. Applicable large employers with 50-99 employees may qualify for an additional one-year delay, until 2016, if certain eligibility conditions are met.
Coverage provided on or after Jan. 1, 2015	Reporting of Health Insurance Coverage ACA requires any person who provides “minimum essential coverage” to an individual during a calendar year to report certain health insurance coverage information to the IRS. The first information returns will be filed in 2016.

2018
EFFECTIVE DATE	ACA PROVISION
Jan. 1, 2018	High Cost Plan Excise Tax A 40 percent excise tax (also known as a “Cadillac tax”) is to be imposed on the excess benefit of high-cost employer-sponsored health insurance. The annual limit for purposes of calculating the excess benefits is $10,200 for individuals and $27,500 for other than individual coverage. Responsibility for the tax is on the “coverage provider,” which can be the insurer, the employer or a third-party administrator.

This Legislative Brief is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. 

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