When the Affordable Care Act (ACA) was signed in March of 2010, it became essential to develop ACA compliance timelines, which consistently pointed to 2014 as the big year for the roll out of ACA’s key provisions. Some of the pressure was eased when the Pay or Play requirements were delayed until 2015, but there are still many other changes that plan sponsors and insurance carriers must comply with beginning in 2014, or be subject to penalties under Internal Revenue Code Section 9815 (such as preventive care, et al.).

The following table summarizes the ACA provisions that become effective in 2014:

Provision Effective Date Description
Individual Mandate January 1, 2014 Taxpayers are assessed a penalty for any months they or their tax dependents do not have EHB coverage.
Marketplaces and
Medicaid Expansion
January 1, 2014 Marketplaces coverage begins for individuals and small employers; Medicaid eligibility is expanded to individual’s age 19 to 65 (including adults without dependent children) with incomes up to 138% FPL.
Ban on annual limits on EHB coverage PYB Jan. 1, 2014 All annual limits on the dollar value of EHB coverage are now completely prohibited (including self-funded and GF plans); Those companies that applied and received annual limits waivers must now comply with the provision.
Excessive waiting period prohibition PYB Jan. 1, 2014 Waiting periods for health coverage eligibility must not exceed 90 days (60 days in California).
PCE prohibition PYB Jan. 1, 2014 Plans are prohibited from denying coverage for pre-existing conditions for all individuals (all ages).
Elimination of the grandfathered plan exception for adult children to age 26 PYB Jan. 1, 2014 Grandfathered plans can no longer deny coverage to dependent children under age 26 based on their eligibility for other coverage.
Small group comprehensive health coverage requirement PYB Jan. 1, 2014 Small group non-grandfathered insured plans must provide benefits from the four levels of EHB options: Bronze, Silver, Gold, and/or Platinum.
Out-of-pocket and deductible maximums for EHB coverage PYB Jan. 1, 2014 Out-of-pocket maximums cannot be greater than that allowed for HSA eligible HDHPs (non-grandfathered, large and small group); Maximum deductibles for 2014 will be $2,000 for single coverage and $4,000 for any other coverage (non-grandfathered, small group only).
Nondiscrimination based on health status PYB Jan. 1, 2014 Non-grandfathered plans are prohibited from establishing rules for eligibility based on certain health status-related factors.
Nondiscrimination against health care providers PYB Jan. 1, 2014 Non-grandfathered plans may not discriminate against providers operating within their scope of practice.
Coverage for clinical trials PYB Jan. 1, 2014 Non-grandfathered plans must cover routine patient costs for care related to clinical trials.
Regulation of premium rates and redistribution of costs PYB Jan. 1, 2014 Fully insured non-grandfathered group plans must adhere to minimum premium rating rules (adjustments can only be made for geographical area, age, and tobacco use).
Guarantee issue and renewability of coverage regardless of health status PYB Jan. 1, 2014 Insurers in the individual or group markets (non-grandfathered, large and small group) are required to accept every employer and individual in the state that applies for coverage.
Wellness program rewards up to 30% PYB Jan. 1, 2014 Wellness incentives up to 30% of individual COBRA rate permitted (50% for tobacco cessation programs).
HPID ID Compliance deadline: large group Nov. 5, 2014 Deadline for insurers and self-funded large group plans to obtain their Health Plan Identifier number (HPID) to be used according to ACA’s expansion of HIPAA’s electronic transaction rules.
Reinsurance Payments Reporting due by Nov. 15, 2014; Payment due by Jan. 15, 2015 Insurers and self-funded plans must pay an annual fee to fund state reinsurance entities establishing a high-risk pool.
Automatic Enrollment Postponed Employers with 200 or more full time employees must automatically enroll new full time employees in the group health plan.
Employer Pay or Play tax and noncompliance penalties (other than discrimination) Postponed Employers with 50 or more full-time employees may incur penalties for not offering affordable health care coverage that meet the minimum value requirements.
Large employer reporting of health care coverage for full time employees Postponed Large employer plans must report full time employee MEC coverage information to the IRS and send written notice to participants.
Self-funded plans and insurers reporting of health insurance coverage Postponed Self-insured plans and insurers must report employee health care coverage and send written notice to participants.