Health Care Reform

On March 23, 2010, President Obama signed into law the health care reform bill, the Patient Protection and Affordable Care Act. This legislation, along with the Health Care and Education Reconciliation Act of 2010, makes sweeping changes to the U.S. health care system. These changes will be implemented over the next several years.

Higginbotham is committed to providing frequent updates on health care reform activity so you can plan accordingly and remain in compliance. Check back here often for the most recent legislative changes.


Leading News

Starting January 1, 2015, Applicable Large Employers (ALEs) (under § 6056), self-insured plan sponsors and any other entity that provides Minimum Essential Coverage (under § 6055) must report information on that coverage to the IRS and their full-time employees.  Both filings provide information regarding available employer-sponsored coverage.  The first returns will be due in 2016 for coverage provided in 2015. Even though these reports are not due until 2016, ALEs that are subject to the Employer Mandate will need to start capturing data this January to be able to fill out these reports accurately.



Health Care Reform Timeline—A detailed summary of requirements through 2018
Reporting Requirements for Employers and Health Plans
2015 Compliance Checklist
Employer Reporting of Health Coverage— Code Sections 6055 and 6056
Documenting Method for Identifying Full-Time Employees


Health Care Reform Activity

Oct. 31, 2014—HPID Requirement Delayed Indefinitely
Oct. 14, 2014—Annual Medicare Part D Notices Due by Oct. 14
Sept. 18, 2014—IRS Expands Rules for Mid-Year Election Changes Under Cafeteria Plans
Sept. 18, 2014—Paying PCORI Fees: Corrections and Amendments
Sept. 2, 2014—Pay or Play Penalty: When to Begin Tracking Employee Hours
Sept. 2, 2014—90-day Waiting Period Limit: Permitted Orientation Periods
Sept. 2, 2014—Pay or Play Penalties: Look-back Measurement Method Examples
Aug. 28, 2014—Draft Instructions for Employer Reporting of Health Coverage Released
July 31, 2014—Patient-Centered Outcomes Research Institute (PCORI) Fees
June 30, 2014—Supreme Court Rejects Contraceptive Mandate for Some Companies
May 2, 2014—Agencies Release New COBRA Guidance for Individuals and Employers
Apr. 1, 2014—Annual Deductible Limit Repealed for Small Health Plans
Mar. 5, 2014—Final Rules Released on Reporting for Issuers and Self-funded Employers
Feb. 12, 2014—Employer Mandate Delayed Until 2016 for Medium-sized Employers 
Feb. 10, 2014—Final Employer Shared Responsibility Regulations Issued
Jan. 1, 2014—90-Day Waiting Period Limit
Dec. 19, 2013—New Options for Individuals Whose Policies Have Been Canceled
Nov. 14, 2013—White House Announces Transition Policy for Canceled Health Plans
Oct. 31, 2013—Changes to “Use-or-lose” Rule for Health FSAs
Oct. 1, 2013—Exchange Notice Requirements for Employers
Sept. 11, 2013—FAQ on Exchange Notice Penalties
Aug. 27, 2013—IRS Issues Final Rules on Individual Mandate Penalties
July 2, 2013—Employer Mandate Penalties Delayed Until 2015
May 29, 2013—Agencies Issue Final Rules on Workplace Wellness Programs
May 8, 2013—DOL Issues Model Exchange Notice and Sets Compliance Deadline
May 3, 2013—Proposed Rule Released on Minimum Value and Affordability
Jan. 24, 2013—DOL Delays Exchange Notice Requirements
June 28, 2012—Supreme Court Upholds Health Care Reform Law
May 30, 2012—IRS Provides Guidance on $2,500 Health FSA Limit
Mar. 23, 2012—Health Plan Summary of Benefits and Coverage
Feb. 9, 2012—Status of DOL Model FMLA Forms 
Dec. 2, 2011—Final Regulations Issued on Medical Loss Ratio
Nov. 14, 2011—IRS Q&A on Form W-2 Reporting
July 8, 2011—Interim Final Rule on Administrative Simplification
June 24, 2011—DOL Amends Interim Final Rule on Appeals Process
June 17, 2011—Waiver Program for Annual Limits Will Close to Applications