Jim Murray
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  Sean Schubert
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  • Grandfathered Plan Requirements
  • Early retiree reinsurance
  • Temporary high risk pool
  • HHS Consumer web portal
  • Preexisting Condition Exclusion prohibition for those under age 19
  • Annual/lifetime limits prohibited on essential benefits (some annual limits may apply until 2014)
  • Rescission prohibition
  • Preventive health services
  • Dependent coverage for children under age 26
  • Nondiscrimination for insured plans application/enforcement – delayed pending additional guidance. Agencies have indicated that employers are not required to comply with this requirement until regulations are issued.
  • Appeals process
  • Patient protections (primary care provider designations, ER services, etc.)
  • Ensuring that consumers get value for their dollars (rate review)
  • Automatic enrollment - no specific effective date. In sub-regulatory guidance, the DOL has indicated that employers are not required to comply with this requirement until regulations are issued.
  • Small business healthcare tax credit
  • Tax-free coverage to children under age 27 (see above regarding coverage mandate to age 26)


  • Expansion of Preventive Services under Medicare
  • OTC drug limits
  • Simple cafeteria plans
  • HSA/Archer MSA penalty tax increase
  • W-2 reporting (voluntary for 2011 tax year)
  • Bringing down cost of coverage (reporting and rebates) – Minimum Loss Ratios
  • Small business grants to provide wellness programs


  • New, voluntary options for Long Term Care Insurance (postponed indefinitely)
  • Distribution of four-page Summary of Benefits and Coverage and Uniform Glossary
  • Quality of care reporting – delayed pending regulations
  • W-2 reporting (mandatory for 2012 tax year)


  • HIPAA electronic transaction standards
  • Health FSA cap
  • Loss of tax exclusion of Medicare Part D drug subsidy
  • Increase in Code § 213 medical deduction
  • New Medicare hospital insurance tax of 0.9 percent on high income individuals*
  • New 3.8 percent Medicare payroll tax on unearned income for high income individuals*
  • First payment of Patient Centered Outcomes Research Institute Fee is due. Fee increases from $1 per participant to $2 per participant for plan years beginning on or after November 1, 2012.
  • Notices to employees about Exchanges and subsidies
  • Co-ops

  • *$200,000 individual, $250,000 joint


  • Exchanges
  • Transparency in coverage (QHP) reporting – reporting begins after QHPs have been in place one calendar year
  • Fair health insurance premiums
  • Guaranteed availability of insurance coverage
  • Guaranteed renewability of coverage
  • Preexisting Condition Exclusion prohibition (for all enrollees)
  • Nondiscrimination based on health status
  • Nondiscrimination against healthcare providers
  • Comprehensive health insurance coverage
  • Cost-sharing limitations
  • Prohibition on excessive waiting periods
  • Coverage for clinical trials
  • Annual/lifetime limits prohibited on essential benefits
  • Increase in small business healthcare tax credit
  • Provision of additional information (Quality Reporting) - reporting required no earlier than reporting required for QHPs (see above)
  • Individual mandate


  • Employer Shared Responsibility
  • Health insurance reporting coverage
  • First payment of Transitional Reinsurance Fee is due
  • First payment of Health Insurance Providers Fee is due


  • High cost coverage tax