ACA Timeline: What Employers Should Know


The coming years will be pivotal for the Affordable Care Act (ACA), so here’s a look at some upcoming dates that will bring about key changes in the health-care market:

July 2015: Small business reimbursement prohibition penalties/enforcement begins. There is a prohibition from reimbursing employees for individual health insurance. Here are the facts:

1. 18 percent of all businesses reimburse for individual health insurance.

2. 14 percent of non-offering businesses reimburse for individual health insurance.

3. Stand-Alone Health Reimbursement Accounts (HRAs) are prohibited except for retirees.

4. The Internal Revenue Service (IRS) ruled that the reimbursement violates the annual and lifetime caps on benefits.

5. Penalties: $100 per employee per day ($36,500 per employee per year)

6. Prohibition was scheduled to begin January 1, 2014; however, it was postponed until July 2015.

7. Exception: Reimbursing retirees or reimbursement occurs for only one employee.

8. Payment of employee costs on an after-tax basis is permitted.

9. Cash offers to employees with high claims risk is prohibited and violates the HIPAA nondiscrimination rules.

November 1, 2015: Open enrollment for 2016 calendar year begins.

January 1, 2016: Employer mandate coverage requirement fully implemented (50-plus full-time employees); must offer to 95 percent of employees and dependents. Small group market/SHOP exchanges expand to mid-size businesses (50-99 full-time employees).

January 31, 2016: Open enrollment for 2016 calendar year ends.

2017: Small Business (SHOP) exchange marketplaces may open for large businesses. Federal Medicaid contribution declines from 100 percent to 95 percent.

2018: Cadillac Tax on high-value plans begins. Here are the facts:

1. Little guidance yet

2. 40 percent non-deductible excise tax

3. Triggered is aggregate cost of employer-sponsored coverage for employee that exceeds the annual limitation (in 2018, it is $10,200 for single; $27,500, other
than single).

4. Subject to adjustments in 2019 and thereafter.

5. Applies to insured and self-insured plans, health flexible spending accounts, medical saving accounts, health reim-bursement accounts and probably health savings accounts.