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2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2016 | 2017 | 2018

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2010

January

    • Small Employer Tax Credit
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Employers with 25 or fewer full-time equivalent employees who earn $50,000 or less on average may earn a tax credit if the employer provides health coverage and pays at least 50% of the premium cost. Self-employed individuals and their wages are not taken into account. The credit is available for any coverage in 2010 to 2013. Beginning in 2014, the employer must purchase Exchange coverage. The tax credit will only be available for the first two years of Exchange coverage. 1/1/2010 Y
      More on this topic.

March

    • Only limited changes may be made to plans to maintain grandfathered status
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Grandfathered status is available for health plans that were providing coverage as of March 23, 2010. Making certain changes to benefit offerings, plan design, or employer contributions toward the cost of coverage will cause a plan to lose its grandfathered status. Grandfathered plans do not have to comply with several plan design mandates imposed by Health Care Reform. The plan sponsor must maintain certain documentation and include notice of grandfathered status in any participant materials describing the coverage. 3/23/2010 Y
      More on this topic.
    • Adult children may receive tax-free health coverage/reimbursement
      DescriptionEffective DateApplies to grandfathered plans?
      Category: FSA/HSA/HRA Provisions
      In addition to the requirement to provide health coverage for adult children, Health Care Reform extended eligibility for tax-free employer-sponsored health coverage/reimbursement for adult children until the end of the calendar year in which a child turns age 26. Participants in Health FSAs or HRAs may be reimbursed for medical expenses incurred for these individuals. Coverage or reimbursements provided on or after 3/30/2010 Y
      More on this topic.

September

    • Pre-existing condition exclusions for children prohibited
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans may not impose any pre-existing condition exclusions for enrollees under age 19. First plan year beginning on or after 9/23/2010 Y
      More on this topic.
    • Lifetime limits prohibited
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans may not impose any lifetime limits on the dollar value of essential health benefits. Individuals who had exhausted their lifetime limits must be allowed to re-enter the plan. Regulations impose notice and special-enrollment rules for such individuals. First plan year beginning on or after 9/23/2010 Y
      More on this topic.
    • Annual limits restricted
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans may impose annual dollar limits on essential health benefits no lower than: $750,000 for plan years beginning on or after September 23, 2010; $1.25 million for plan years beginning on or after September 23, 2011; and $2 million for plan years beginning on or after September 23, 2012. Annual limits are prohibited for plan years beginning on or after January 1, 2014. First plan year beginning on or after 9/23/2010 Y
      More on this topic.
    • Rescissions generally prohibited
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans may not retroactively terminate (rescind) coverage except in limited circumstances, such as for an individual who commits fraud or makes intentional misrepresentations of material facts as prohibited by the terms of the plan. Even in cases where permitted, plans must provide participants with written notice 30 days before coverage is retroactively terminated. First plan year beginning on or after 9/23/2010 Y
      More on this topic.
    • Must cover adult children to age 26 (special rule available for grandfathered plans)
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans that cover children must provide coverage to adult children up to age 26 (regardless of marital status, student status, residency, or parental support). Coverage does not have to be provided to the adult child's spouse or children. A grandfathered plan is not required to extend coverage to an adult child who is eligible for other employer-sponsored coverage until 2014. First plan year beginning on or after 9/23/2010 Y
      More on this topic.
    • Insured plans may not discriminate in favor of highly compensated individuals
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Fully-insured, non-grandfathered plans may not discriminate in favor of highly compensated individuals. (Self-funded health plans are subject to similar nondiscrimination rules, whether grandfathered or non-grandfathered.) First plan year beginning on or after 9/23/2010 (IRS enforcement delayed until guidance is issued) N
      More on this topic.
    • Must cover preventive care without cost-sharing
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Non-grandfathered plans cannot require cost-sharing (such as copayments or deductibles) for preventive care services that are specified by the federal government, including immunizations. First plan year beginning on or after 9/23/2010
      Plans must cover newly-added services with the first plan year beginning on or after the new reccomended guideline is published
      N
      More on this topic.
    • Must allow individuals to choose their PCPs/pediatricians
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans can require participants to designate a primary care physician or pediatrician, but participants of non-grandfathered plans must be permitted to designate any primary care physician or pediatrician participating in the plan's provider network. First plan year beginning on or after 9/23/2010 N
      More on this topic.
    • Must allow access to OB/GYN without referral
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Non-grandfathered plans cannot require females to receive preauthorization for OB/GYN services. Notice requirements apply. First plan year beginning on or after 9/23/2010 N
      More on this topic.
    • Must provide direct access to/coverage for emergency services
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Non-grandfathered plans cannot require preauthorization for emergency services, limit coverage to only in-network providers, or impose higher cost-sharing for emergency services from an out-of-network provider. First plan year beginning on or after 9/23/2010 N
      More on this topic.
    • Transparency disclosures
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Non-grandfathered plans must provide certain information to HHS and the public, such as claims payment policies and practices, data on specified topics (e.g., enrollment, disenrollment, claims denied, and rating practices), financial disclosures, information on cost-sharing, and payments with respect to out-of-network coverage, and information on participants' rights under Health Care Reform. First plan year beginning on or after 9/23/2010. However, guidance moved this date to 2015, based on 2014 data. Future guidance will clarify the exact date. N
      More on this topic.
    • Must follow new internal and external claims procedures
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Non-grandfathered plans must comply with new internal and external claims procedures - improved internal claim review procedures and a new requirement for external review. External review decisions are binding on the plan or insurer.

      First plan year beginning on or after 9/23/2010. Effective date was delayed for certain requirements until plan years beginning on or after 1/1/2012.

      N
      More on this topic.
    • Must provide patient protection notices
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Plan sponsors must provide certain notices to employees in connection with the requirement to eliminate any lifetime limits, extend eligibility to adult children, and for non-grandfathered plans, provide direct access to certain providers, such as out-of-network emergency facilities. First plan year beginning on or after 9/23/2010 N
      More on this topic.
    • Grandfathered plans must comply with notice and documentation requirements.
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions

      Plan sponsors treating certain health coverage options as grandfathered must maintain records documenting the terms of coverage in effect on March 23, 2010, and any necessary substantiating documentation. In addition, any materials provided to participants or beneficiaries that describe the health coverage must include notice that the coverage is grandfathered.

      Due date is unclear, but presumably must be provided at the beginning of the year the employer is first claiming grandfathered status Y
      More on this topic.
    • 30-day open enrollment
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Plans must offer a minimum of 30 days for open enrollment for the first plan year beginning on and after September 23, 2010. The purpose is to provide an adequate opportunity to enroll for individuals who were previously excluded from the plan due to the imposition of lifetime limits or age. Notice requirements also apply. Required only for the first plan year beginning on or after 9/23/2010 N
      More on this topic.

2011

January

    • Over-the-counter drugs may only be reimbursed with a prescription
      DescriptionEffective DateApplies to grandfathered plans?
      Category: FSA/HSA/HRA Provisions
      Reimbursements for over-the-counter (OTC) drugs and medicines are permitted only with a medical practitioner's prescription. Restrictions also apply to use the debit cards to purchase OTC drugs and medicines. 1/1/2011 Y
      More on this topic.
    • HSA penalty for non-qualified distributions increased
      DescriptionEffective DateApplies to grandfathered plans?
      Category: FSA/HSA/HRA Provisions
      Withdrawals from HSAs not used for qualified medical expenses are subject to a 20% excise tax, which is an increase from 10% under prior law. Distributions made after 12/31/2010 Y
      More on this topic.
    • Prescription drug manufacturer annual fee (may increase employer costs)
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Brand name prescription drug manufacturers must pay an annual fee based on their prescription drug sales. Costs are likely to be passed on to plan sponsors in the form of increased brand name prescription drug costs. 1/1/2011 Y
      More on this topic.
    • Small employer wellness grants
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Employers with less than 100 employees who work 25 hours or more per week that did not provide a wellness program on March 23, 2010 may apply for grants to establish workplace wellness programs. The program must satisfy certain requirements. HHS will develop specific criteria for qualified programs and the application process. The grant program is available from 2011 through 2015. Y
      More on this topic.

September

    • Comparative Effectiveness Research Fee
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Plan sponsors of self-funded health plans and insurers of insured health plans must pay a fee to help fund the Patient-Centered Outcomes Research Institute based on the average number of lives covered in the plan. The fee is $1 per individual for the first plan or policy year ending after September 30, 2012., and $2 per plan participant for the next plan or policy year. For subsequent plan or policy years the $2 fee will be indexed to cost increases in per-capita "national health expenditures". The fees don't apply to plan or policy years ending after September 30, 2019. For calendar year plans, fees will be due for the 2012-2018 plan years. First plan or policy year ending after 9/30/2012 and continuing for seven plan or policy years until expiring 9/30/2019. Y
      More on this topic.

2012

January

    • Form W-2 reporting of employer-sponsored health coverage for large employers
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Employers must report the cost of employer-provided health coverage on employees' W-2 Forms. The reporting does not make the coverage taxable to employees. Employers filing 250 or more Forms W-2 for the 2011 calendar year are required to report beginning with the 2012 tax year (W-2s to be provided at the beginning of 2013). Smaller employers are not required to report until further notice. Y
      More on this topic.
    • Medical device fee (may increase employer costs)
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Medical device manufacturers, producers, or importers must pay an excise tax equal to 2.3% of the sale price on the sale of certain medical devices. Costs are likely to be passed on to plan sponsors in the form of increased medical device costs. Sales after 12/31/2012 Y
      More on this topic.
    • Medical loss ratio (MLR)
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Health Care Reform establishes Medical Loss Ratio (MLR) targets for health insurance coverage offered in the individual, small group, and large group markets. If a health insurer does not achieve the target MLR, it must provide rebates to enrollees in that market. Employers that receive a rebate must allocate to employees a sum that is proportionate to their individual premium contributions. Reporting begins in 2011, rebating in 2012. Insurance companies must pay required rebates by 8/1 each year. Y
      More on this topic.

March

    • Summary of Benefits and Coverage (SBC) and Uniform Glossary
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Plan sponsors for self-funded plans and insurers for fully insured plans must provide a Summary of Benefits and Coverage (SBC) and Uniform Glossary to plan participants. If the plan is fully insured the plan sponsor shares responsibility with the insurer for distributing the SBC. Annual enrollments and plan years beginning on or after September 23, 2012. Y
      More on this topic.
    • Must provide 60-day advance notice of benefit changes
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      If any material modifications in health plan coverage of the items listed on the SBC, such as increases in cost-sharing or benefit reductions, are made mid-year that are not reflected in the most recently distributed Summary of Benefits and Coverage (SBC), the plan sponsor must send notice of the changes to plan participants at least 60 days before the modifications become effective. Plan years beginning on or after September 23, 2012 Y
      More on this topic.

2013

January

    • Health FSA contributions limited*
      DescriptionEffective DateApplies to grandfathered plans?
      Category: FSA/HSA/HRA Provisions
      The amount employees may contribute to a Health FSA is capped at $2,500 per year, indexed for inflation. Only employee, not employer, contributions are subject to the new limit. Plan years beginning on or after 1/1/2013 Y
      More on this topic.
    • Additional Medicare Tax
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Requirements
      Employers must withhold additional 0.9% Medicare tax on wages paid to employees in excess of $200,000. 01/01/2013 Y
      More on this topic.
    • Employer deduction for Medicare retiree drug subsidy eliminated
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Employers that provide prescription drug coverage to Medicare-eligible retirees that is at least as valuable as the Medicare Part D benefit are eligible for a subsidy of 28% of allowable prescription drug claims. In effect, this subsidy has been tax-free for employers. However, beginning with the 2013 tax year, an employer's allowable deduction for retiree prescription drug expenses must be reduced by the amount of the tax-free subsidy payment received. This provision had an accounting impact in 2010 when the Health Care Reform law was enacted. Taxable years beginning after 12/31/2012 Y
      More on this topic.

March

    • Quality reporting guidance due
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Plan sponsors of non-grandfathered plans must report on plan benefits and reimbursement structures that provide certain quality-related programs like disease management. Reports must be issued annually to HHS and to employees during open enrollment. HHS to establish effective date and other requirements
      More on this topic.

July

    • First PCORI Fee Due
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Plan sponsors of self-funded health plans and insurers of ully-insured health plans must pay a fee to help fund the Patient-Centered Outcomes Research Institute. The fee must be reported and paid by filing tax Form 720 by 7/31 following the plan year for which a fee is due. The fee applies for plan years ending after 9/29/2012 until expiring 9/20/2019. Form 720 is due by 7/31 following the end of the plan year for which a fee is due. Y
      More on this topic.

October

    • DOL Issues Model Exchange Notice
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Requirements
      Under Health Care Reform, employers are required to provide current employees and new hires a notice explaining Exchanges. Employers are required to provide the notice to all employees regardless of full or part time status by October 1, 2013, and upon hire for new employees after October 1, 2013. Starting January 1, 2014 employers will have up to 14 days from the date of hire to provide the notice to new employees Y

      More on this topic.

2014

January

    • Health Insurance Exchange coverage available for individuals/small employers
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      States must establish Health Insurance Exchanges to offer private insurance choices to individuals and small employers (generally with 100 or fewer employees). 1/1/2014, If a state chooses not to build an Exchange, the Federal government will operate an Exchange in that state. Y
      More on this topic.
    • Federal Premium Tax Credit to purchase Exchange coverage
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Federal premium tax credits to buy Exchange coverage are available to certain individuals with household income up to 400% of the Federal Poverty Level. Effective 1/1/2014. Y
      More on this topic.
    • Individuals must obtain minimum essential benefits coverage or pay a penalty
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      All individuals must obtain minimum essential coverage or pay penalty. Exemptions apply for certain individuals, such as if employer coverage is unaffordable (costs more than 9.5% of household income), for low-income taxpayers, and for short coverage gaps. In addition, a federal premium tax credit to purchase Exchange coverage is available for certain individuals with household income up to 400% of the federal poverty level. If an individual is covered by a non-calendar year, employer-sponsored plan, the penalty will not apply until the first day of the calendar year in 2014. 1/1/2014 Y
      More on this topic.
    • Health insurance company annual fee (may increase employer costs)
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      Insurance companies must pay an annual fee based on the amount of premiums they receive. Costs are likely to be passed on to plan sponsors in the form of increased premiums. 1/1/2014 Y
      More on this topic.

January (plan years beginning on or after)

    • Exchange Reinsurance Fee
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      For three years beginning in 2014, health insurers of fully-insured and plan sponsors of self-funded non-grandfathered group health plans will be required pay reinsurance fees to HHS. The purpose of the fee is to help stabilize premiums for coverage in the individual market during the first three years of Exchange operation. For three years beginning 1/1/2014 N
      More on this topic.
    • Waiting periods over 90 days prohibited
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans may not impose an eligibility waiting period of greater than 90 days. First plan year beginning on or after 1/1/2014 Y
      More on this topic.
    • Annual limits prohibited
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans may not impose any annual dollar limits on essential health benefits. (Prior to 2014, annual limits are restricted.) First plan year beginning on or after 1/1/2014 Y
      More on this topic.
    • Pre-existing condition limits for adults prohibited
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Plans may not impose any pre-existing condition exclusions for any enrollees. (Prior to 2014, plans are only prohibited from imposing pre-existing condition limits for enrollees under age 19.) First plan year beginning on or after 1/1/2014 Y
      More on this topic.
    • Grandfathered plans must cover all children to age 26
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Grandfathered plans that cover dependents must offer coverage for adult children up to age 26 regardless of eligibility for other employment-based coverage. First plan year beginning on or after 1/1/2014 Y
      More on this topic.
    • Incentive for wellness participation increases to 30%
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Under the HIPAA wellness rules, an employer may currently offer financial incentives to participate in wellness programs up to 20% of the cost of health plan coverage. Beginning in 2014, the 20% cap is increased to 30% with federal agency discretion to increase it to 50%. First plan year beginning on or after 1/1/2014 Y
      More on this topic.
    • May not discriminate against individuals in clinical trials
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      With respect to individuals who participate in clinical trials, non-grandfathered plans may not deny participation in a clinical trial, limit coverage for routine items and services typically covered for individuals who are not enrolled in clinical trials, or discriminate against individuals based on their participation in clinical trails. Plans do not have to pay for the investigational item, device, or service itself. First plan year beginning on or after 1/1/2014 N
      More on this topic.
    • Insured small group plans must comply with limits on deductibles (REPEALED)
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      The law prohibited non-grandfathered insured, small group plans from imposing deductibles higher than $2,000 for individual coverage or $4,000 for family coverage. However, this requirement was repealed in April 2014 as part of the "Protecting Access to Medicare Act of 2014". Repealed N
      More on this topic.
    • Must comply with limits on out-of-pocket maximums
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Non-grandfathered plans may not require a participant to pay cost-sharing (e.g., deductibles, copayments, coinsurance) in excess of the out-of-pocket maximum that applies to HSA-compatible high deductible health plans (in 2014, $6,350 for individual coverage or $12,700 for family coverage). First plan year beginning on or after 1/1/2014 N
      More on this topic.
    • Insured small group plans must cover all essential benefits
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Non-grandfathered, small group insured plans must provide coverage for all essential benefits, to be defined by federal regulations. First plan year beginning on or after 1/1/2014 N
      More on this topic.
    • May not discriminate against providers acting with the scope of their licenses
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Design Mandates
      Non-grandfathered plans may not discriminate against health care providers acting within the scope of their licenses. For example, this could prevent a plan from denying benefits solely because a doctor prescribed a drug for an off-label purpose or provided a service outside the doctor's typical specialty area (assuming both acts were within the scope of the doctor's license). First plan year beginning on or after 1/1/2014 N
      More on this topic.

2015

January

    • Transparency disclosures
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Non-grandfathered plans must provide certain information to HHS and the public, such as claims payment policies and practices, data on specified topics (e.g., enrollment, disenrollment, claims denied, and rating practices), financial disclosures, information on cost-sharing, and payments with respect to out-of-network coverage, and information on participants' rights under Health Care Reform. First plan year beginning on or after September 23, 2010. However, guidance moved this date to 2015, based on 2014 data. Future guidance will clarify the exact date. N
      More on this topic.
    • Free Rider Penalty
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      An employer with 100+ full-time equivalent employees (50+ in 2016 and beyond)that does not offer health coverage to substantially all full-time employees (30+ hours per week) and their dependent children, or offers coverage that is either unaffordable (the premium contribution to receive employee-only health coverage from the employer costs the employee more than 9.5% of household income) or inadequate (the coverage has an actuarial value of less than 60%). The employer will only owe a Free Rider Penalty if at least one employee enrolls in Exchange coverage and qualifies for a premium tax credit. Note that coverage must be offered to biological and adopted children to age 26 in order to avoid triggering a Free Rider Penalty. Effective 1/1/2015; however, for any employee for whom the employer offers adequate and affordable coverage by the first day of the plan year beginning in 2015, no penalty will be due prior to the beginning of the plan year beginning in 2015. Y
      More on this topic.
    • Coverage and Workforce Reporting
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Employers with 50+ full-time employees must submit reports to the IRS with extensive details about the employer's health coverage and the employer's workforce. Certain reporting is also required for plan sponsors that provide minimum essential coverage, even if the employer has fewer than 50 employees. Reports must include data beginning 1/1/2015. The first reports will be due in 2016. Y
      More on this topic.
    • Automatic enrollment
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Administrative Provisions
      Plan sponsors with 200+ full-time employees must automatically enroll their full-time employees in employer-sponsored health coverage. If an employee wants different or no health coverage, they will be able to change or opt out of the employer's plan. The employer will be required to send notices to employees regarding the automatic enrollment process. Effective date is unclear - expected to be established by regulations, which the agencies have indicated will be sometime after 2014. Y
      More on this topic.

2016

January

2017

January

2018

January

    • Excise tax on high cost plans (Cadillac Tax)
      DescriptionEffective DateApplies to grandfathered plans?
      Category: Plan Sponsorship Provisions
      A 40% nondeductible excise tax will be imposed to the extent the aggregate value of specified employer-sponsored health coverage exceeds certain threshold amounts – generally, $10,200 for individual coverage and $27,500 for family coverage. Although the excise tax generally will be paid by insurers and/or third party administrators, the amount of the tax is expected to be passed through to the employer sponsoring the high cost plan(s). 1/1/2018 Y
      More on this topic.

American Fidelity Assurance Company does not provide tax or legal advice.

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