The Inside Track: Health care reform
Distribute Summary of Benefits and Coverage
  • Starts first open enrollment after 9/23/12
  • Provide 60-day advance notice on any material modification

Manage distribution of Medical Loss Ratio (MLR) rebates

Report health coverage value on 2012 employee W-2s (for distribution in 2013)
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Limit Flexible Spending Account deductions to $2,500

Deduct additional Medicare taxes for high-income employees
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Notify employees about Health Insurance Exchanges, options and impacts
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Understand new fees: medical device manufacturer levy and Patient-Centered Outcomes Research Institute (PCORI) fee
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Determine whether or not you’ll offer health coverage through the Small Business Health Options Program (SHOP) exchange (if applicable — small businesses only)

Prepare for health insurance sector fee and Transitional Reinsurance Program fee
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Make sure your health plan meets new requirements:
  • Cover essential health benefits
  • Comply with cost-sharing limits
  • Comply with waiting-period restrictions
  • Do not exclude people based on pre-existing conditions
  • Cover dependents to age 26
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Institute auto enrollment for group health plans (effective date to be determined)
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Revisit your benefits strategy in light of the individual mandate and the Health Insurance Exchanges
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For employers with 100 or more employees: Decide whether to pay or play.

laptop Our online interactive guide walks you through the steps.
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Report employer provided health insurance to IRS
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Consider new plan options through the SHOP exchanges
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For employers with 50-99 employees:
Decide whether to pay or play.

Understand SHOP expansion
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Check on SHOP for larger employers (100+ lives)
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Calculate any "Cadillac tax" liability
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  • Consult with your benefits attorney/legal counsel to discuss your obligations and options.
  • Consult with your broker to determine communication strategy.