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Blog By: Beth Ede, SPHR

Is it a time to sit back and wait or is it business as usual? 


As the Supreme Court considers whether the Anti-Injunction Act bars them from taking up the issue of the constitutionality of the individual mandate until 2014; whether the individual mandate is constitutional; and whether the remainder of the health care reform law can stand if the individual mandate is struck down, we may feel like we can “sit back and wait”, but really – it’s business as usual until we hear different.


So, what is “business as usual” for health care reform in the near future?  Below are just a few mandates that are quickly approaching and applicable employer groups should be preparing:


§  Women’s Preventive Services Expansion

o   Effective August 1, 2012 (with extended one year transition period for some religious organizations)


§  Uniform Summary of Benefits and Coverage (SBC)

o   Effective with renewal date and/or open enrollment date period on or after September 23, 2012


§  Advance Notice of Material Modifications

o   Requires 60-day advance notice of material modifications be provided to employees

o   Effective with the implementation of the SBC requirement dates


§  Comparative Effectiveness Fee

o   Effective for policy years ending on or after 10/01/2012

o   First payment due on or after July 31, 2013 – based on plan year


§  Employer-Provided Health Coverage Informational Reporting Requirement (Form W-2 Reporting Requirement)

o   Effective for the 2012 calendar year reporting for employers who provided 250 or more 2011 Form W-2s


§  Health FSA Contribution Cap ($2,500 annual limit)

o   Effective for 2012 tax year

o   Plan changes may need to be made to accommodate annual limit

Posted 8:44 AM  View Comments

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