Healthcare Reform Timeline View items by selecting blocks on the timeline, or click the arrows.

• Healthcare Reform
  This is a timeline of the effective dates for the major provisions of the Patient Protection and Affordable Care Act as amended by the Healthcare and Education Affordability Reconciliation Act of 2010 (together, the "healthcare reform law"), along with analysis about the effect each provision may have on churches and, specifically, GuideStone health plans.

  Here is the full link to the law.

  2010

  For plan years beginning after September 23, 2010, the following provisions of the healthcare reform law will take effect—most group health plans (including the GuideStone plans) will have to incorporate these changes by January 1, 2011.

  

• Lifetime Limits and Annual Limits

  Who this affects: Participants

  Summary: Group health plans are prohibited from imposing lifetime limits on the dollar value of essential health benefits. Until January 1, 2014, a plan will be permitted to apply certain restricted annual limits on essential health benefits. We expect that the Department of Health and Human Services (HHS) will issue regulations to provide plan sponsors additional guidance about annual limits.

  All but one GuideStone health plan already provide unlimited annual and lifetime benefits. This feature has been part of GuideStone medical plans for more than a decade.

  What this means for you: Under legal review

  

• Dependent Coverage Extended up to age 26

  Who this affects: Participants

  Summary: Group health plans that provide dependent coverage for children must continue to make that coverage available until children reach age 26 (regardless of student status). This coverage must be provided whether or not the child is dependent on the covered parent for support and whether or not the child is married.

  This dependent coverage will be considered a tax-free benefit for the parents' tax year in which the dependent has not attained age 27. This means that employees will not be taxed on the imputed value of it if the employer pays a portion of the premium.

  What this means for you: GuideStone healthcare plans continue to cover dependent children under age 26.

  

• Dependent Tax Information Up To Age 27

  Who this affects: Participants

  Summary: While the Affordable Care Act requires healthcare plans to cover enrollees’ children up to age 26, some employers may decide to continue coverage beyond the child’s 26^th birthday. In such a case, the Act provides that the value of the employer-provided health coverage is excluded from the employee’s income for federal income tax purposes for the entire taxable year in which the child turns 26. Thus, if a child turns 26 in March but stays on the plan through December 31^st, all health benefits provided that year are excluded for federal income tax purposes.

  For state income tax purposes, employers in states with state income tax should determine if or how to report health coverage for dependents for state tax purposes.
  

  What this means for you: How will the new dependent age rule affect my taxes?

  

• Medical Loss Ratios

  Who this affects: Employers

  Summary: Requires health plans to spend at least 80% (individual plans) or 85% (group plans) of premium dollars collected on medical costs.

  What this means for you: Will the implementation of medical loss ratios affect the premiums I pay?

  

• Temporary Retiree Reinsurance Program

  Who this affects: Everyone

  Summary: The federal government has established a temporary reinsurance program to help plans that provide retiree health benefits for retired participants between the ages of 55 and 64 who are not eligible for Medicare. Approved group health plans can request reimbursement from this program to cover up to 80% of claims between $15,000 and $90,000 (as adjusted each year) related to coverage of these early retirees and their dependents. The reinsurance can only be used to reduce costs under the plan. This program is supposed to be available through December 31, 2013. However, Congress provided only $5 billion to fund this program. Once this amount is exhausted, no further reimbursements will be made. GuideStone has applied for the reinsurance funds and has received its first reimbursement. In accordance with GuideStone’s approved application, the reimbursements will help offset rate increases.

  What this means for you: Is there a subsidy for offering health coverage to early retirees? How do I apply for the subsidy?

  

• Rebates for the Part D Coverage Gap

  Who this affects: Participants

  Summary: Effective immediately, Medicare Part D enrollees who enter the coverage gap, or "donut hole," will receive a $250 rebate from the federal government. The "donut hole" is a gap in Medicare Part D coverage between the initial coverage limit and the catastrophic threshold during which the beneficiary must pay 100% of the cost of prescription drugs. Currently, the coverage gap starts when total drug spend reaches $2,830 and ends when the enrollee's total out-of-pocket costs reach $4,550. Medicare Part D enrollees who receive a low-income subsidy from the government will not receive the rebate.

  What this means for you: Do I qualify for a $250 rebate from the government for the Part D Donut Hole?

  

• Preventive Health Services Covered

  Who this affects: Participants

  Summary: Participants in non-grandfathered health plans (such as GuideStone’s) have been provided expanded coverage for certain preventive services as of January 1, 2011. These services may include the following: cancer screenings, routine vaccinations, well-child visits and blood-pressure tests. These services will be provided at no cost or a reduced cost.

  What this means for you: Where can I find out what preventive services are covered?

  

• Temporary Federal High-Risk Pool

  Who this affects: Participants

  Summary: Eligible individuals who do not have other coverage and cannot obtain individual coverage have access to coverage through a federal high-risk pool that does not impose any coverage exclusions for pre-existing health conditions. This federal high risk pool is available until January 1, 2014, when the Health Insurance Exchanges (see 2014 health insurance exchanges) become operational. You can find out more information at www.pcip.gov

  What this means for you: Can I get insurance through the new federal Pre-Existing Condition Insurance Pool?

  

• Certain Pre-Existing Condition Exclusions for Children Prohibited

  Who this affects: Participants

  Summary: Health insurance companies in the individual market and group health plans will be prohibited from imposing pre-existing condition exclusions on coverage for children under age 19.

  What this means for you: If my child has a pre-existing condition, will his or her health coverage be limited for that condition?

  

• Prohibition on Rescissions

  Who this affects: Everyone

  Summary: Insurance providers and group health plans are now prohibited from terminating existing health insurance policies when a covered person becomes sick. Additionally, the law prohibits any retroactive cancellation (or “rescission”) of a participant’s medical coverage except in certain situations: fraud or intentional misrepresentation of a material fact or non-payment of premiums.

  This regulation applies to medical coverage only and does not affect dental, term life or disability coverage.
  

  What this means for you: As an individual with medical coverage through GuideStone's Personal Plans, how can I terminate my medical coverage? As an employer offering medical plan benefits through GuideStone's Group Plans, do the new rescission rules affect the way I terminate employee medical coverage?  Will my medical coverage be canceled if I become sick or have high claims?

  

• Medicaid Flexibility for States

  Who this affects: Participants

  Summary: States will be allowed to expand Medicaid programs—and receive federal assistance for the expanded coverage—to cover parents and childless adults with incomes up to 133% of the Federal poverty level.

  What this means for you: TBD

  

• Grandfathering Status

  Who this affects: Everyone

  Summary: To allow for greater flexibility for employers, GuideStone has chosen not to grandfather our health plans. Because your plans will not be grandfathered, you have the option to keep the same plan if you'd like, or you can change plans when you feel it is appropriate. Additionally, GuideStone's health plans will be able to take advantage of enhanced benefits like preventive care services paid at 100%.

  If GuideStone had chosen to qualify their plans as grandfathered plans, an employer would be required to continue offering relatively the same benefits and contribute the same percentage toward the cost of the plans. This means that in the future, an employer would not be able to change health plans or shift more cost to employees to help moderate rate increases.

  What this means for you: As an employer offering medical plan benefits, can I choose to "grandfather" my plans?

  

• Choosing Your Doctor

  Who this affects: Participants

  Summary: This only applies to plans which utilize a network of providers and which require the designation of a primary care physician (PCP). In such plans, participants are allowed to designate any PCP who is available to accept the patient. If the participant does not choose, the plan is allowed to choose for them. Pediatricians may be chosen as PCP for children and plans can no longer require preauthorization or referral to OB/GYN providers.

  What this means for you: Will the allowance to designate any primary care physician change my plan at all?.

  

• Out-of-Network Services

  Who this affects: Participants

  Summary: Regulations for non-grandfathered group health plans make emergency services more accessible to consumers. Health plans may not impose any administrative requirement or limitation on coverage for emergency services provided by non-network providers that is more restrictive than the requirements or limitations that apply to emergency services received from in-network providers. Furthermore, the copayment or coinsurance cannot exceed the in-network costs of emergency services. Other cost-sharing requirements (including deductible and out-of-pocket maximums) can be imposed on out-of-network emergency services, but only if such cost-sharing requirements generally apply to out-of-network benefits under the plan.

  What this means for you: Does this mean I am not required by GuideStone to alert my plan of emergency room visits?  Does this change the way my GuideStone health plan pays for emergency room care?

  

• Denying Coverage for Individuals Under Age 19

  Who this affects: Participants

  Summary: This new regulation prohibits insurance companies from denying coverage for individuals under age 19 based on pre-existing conditions. Proof of good health will no longer be required for individuals under age 19 to qualify for health insurance.

  What this means for you: Does GuideStone now cover all dependents under age 19 regardless of health status?  Can my dependent under age 19 enroll in a GuideStone health plan at any time?

  
• 2011

  Small Business Healthcare Tax Credit

  Who this affects: Employers

  Summary: Qualified small employers, including small non-profit organizations (those with 25 or fewer employees with an average annual wage less than $50,000), are eligible for a tax credit for their contributions to purchase employees’ health insurance under a qualifying arrangement. For 2010, employers must pay at least 50% of the insurance premiums for all enrolled employees. After 2010, employers must make uniform premium contributions of at least 50% for all enrolled employees. The maximum 2010 credit for non-profit employers is 25% of the employer's contributions. The credit may not exceed the employer's portion of payroll taxes, which includes income tax withholding and Medicare taxes, both the employer and the employee share. The Internal Revenue Service has revised Form 990-T for use by tax-exempt employers to claim the credit and has also provided Form 8941 for additional calculation of the credit. “Special rules” apply in calculating the credit for a tax-exempt qualified employer. The tax credit is also of limited duration: from 2010 to 2013 for health insurance coverage, and from 2014 to 2016 for coverage purchased from a Health Insurance Exchange.

  What this means for you: Churches may qualify for the tax credit. Find more information here.

  

• Filling the Part D Coverage Gap

  Who this affects: Participants

  Summary: Medicare Part D beneficiaries will begin receiving a 50% discount on all brand-name drugs in the "donut hole." The "donut hole" is a gap in Medicare Part D coverage between the initial coverage limit and the catastrophic threshold during which the beneficiary must pay 100% of the cost of prescription drugs. Additional discounts on brand-name and generic drugs will be phased in from 2011 to 2020 so that the donut hole will be eliminated completely by 2020 for all Part D enrollees. As a result, each year the Part D benefit will become more valuable. By 2020, seniors will pay only the standard 25% coinsurance through the entire coverage gap.

  What this means for you:

  I hear the “donut hole” for Medicare Part D drugs will be eliminated by healthcare reform. When will that happen?

  

• Definition of Qualified Medical Expenses Standardized

  Who this affects: Everyone

  Summary: The definition of "qualified medical expenses" will be conformed for health savings accounts (HSAs), flexible spending accounts (FSAs), and health reimbursement arrangements (HRAs) to the definition used for the itemized deduction. This means that over-the-counter drugs will no longer be eligible for reimbursement from any of these accounts. An exception will remain so that amounts paid for over-the-counter medicine with a prescription would still qualify as "qualified medical expenses." Beginning January 1, 2011, Health Savings Account non-qualified withdrawal penalties rose from 10% to 20%.

  What this means for you: TBD

  

• Medicare Advantage Payments Changed

  Who this affects: Participants

  Summary: In 2011, the federal government payments to Medicare Advantage (MA) plans will be frozen at 2010 levels. In subsequent years, the healthcare reform law provides for a gradual decrease in federal funding to certain MA plans, which may result in increased costs (higher premiums or out-of-pocket costs) for retirees in these plans. GuideStone does not offer Medicare Advantage plans.

  What this means for you: TBD

  

• Cafeteria Plan Changes

  Who this affects: Everyone

  Summary: Eligible small employers will be allowed to establish Simple Cafeteria Plans to provide tax-free benefits to their employees. This may ease small employers' administrative burdens in sponsoring a cafeteria plan. Small churches may consider adopting Simple Cafeteria Plans that are easy to administer for the benefit of their employees. We expect guidance to be issued in the future about how to set up a Simple Cafeteria Plan.

  What this means for you: TBD

  

• External Appeals Process

  Who this affects: Participants

  Summary: A new claims appeals process that began January 1, 2011, allows health plan participants the right to appeal decisions, including claims denials and rescissions, made by their health plans. Participants may currently file an appeal to GuideStone after following the internal appeals process at Highmark. We are awaiting guidance as to how the new appeals regulations will affect the current appeals process.

  What this means for you: How do I appeal claims?

  
• 2012

  Uniform Summary of Benefits

  Who this affects: Everyone

  Effective March 23, 2012, all health plans will be required to provide a uniform summary of benefits to participants at initial enrollment and annual enrollment in the plan. In addition, plans will be required to notify participants of material modifications to plan benefits at least 60 days in advance.

  By March 23, 2011, HHS is supposed to provide standards for use in preparing the uniform summary of benefits. These standards should provide guidance on what information must be included in the uniform summary of benefits.

  What this means for you: TBD

  

• 1099 and W-9 Forms

  Who this affects: Employers

  Summary: The Patient Protection and Affordable Care Act (PPACA) contained a provision that would have required businesses that had previously been exempt from filing a Form 1099 to begin doing so in 2013. In April 2011, President Obama signed a measure retroactively repealing this provision. Standard reporting obligations for Form 1099 remain. These generally require payments totaling at least $600 in a single calendar year to a single recipient to be reported to IRS.

  What this means for you: Does my church have to start sending 1099 forms to GuideStone or obtaining W-9 forms from GuideStone?

  

• CLASS Act Program

  Who this affects: Everyone

  Summary: The CLASS Act is a voluntary long-term care program that participants can make contributions to, either directly or through their employer. Employers do not have to offer this program. However, if they do, employees will be automatically enrolled unless they opt out. The specific monetary amount of the program's benefits will not be known until further regulations are released. Enrollments in the CLASS Act program are expected to start in 2012 but benefits will not start until at least 2017.

  What this means for you: Will the CLASS Act affect the long-term care insurance I have with MetLife through GuideStone right now?

  

• Health Coverage Costs Reported on W-2 Forms

  Who this affects: Everyone

  Summary: Employers will be required to disclose the cost of providing employee healthcare coverage on each employee's annual Form W-2 (the value of coverage remains tax-free). Employers who provide coverage through a self-insured church group health plan (including GuideStone coverage) will be exempt from this requirement. However, they may be required to report FSA or HSA contributions made on behalf of employees if they exceed certain amounts. Employers will have to begin providing this information to employees for whom they issue W-2s for 2012 (issued in January 2013). This new rule does not mean that employees will be subject to additional taxes on the health coverage provided by the employer.

  What this means for you: Will a church whose pastor claims 100% of his salary as housing allowance be required to issue the pastor a W-2 for health insurance premiums? Do I have to start reporting the cost of providing my employees' health coverage on their W-2s? Will medical benefits be taxable?

  
• 2013

  Reporting Requirements

  Who this affects: Employers

  Summary: An employer must provide written notice to each employee at the time of hiring (or with respect to current employees, not later than March 1, 2013). Such notice is to provide certain information on the existence of an Exchange and certain information about the employer's plan. We expect guidance on this requirement.

  What this means for you: TBD

  

• Limit on FSA Contributions

  Who this affects: Participants

  Summary: Contributions to health FSAs will be limited to $2,500 per year, indexed to inflation for subsequent years. Churches and other employers will need to amend their plans to account for this limit. They will also need to communicate these changes to participants in 2012 before participants make their 2013 FSA elections.

  What this means for you: TBD

  

• Employer Part D Subsidy Tax Deduction Ends

  Who this affects: Employers

  Summary: The tax deduction will be eliminated for the Medicare Part D retiree drug subsidy (RDS) available to for-profit employers that maintain prescription drug plans for their Medicare Part D eligible retirees. Losing the tax-exempt benefit to the RDS may lead many for-profit employers to terminate drug coverage for their retirees (sending their retirees to Medicare Part D). Though this will not directly impact tax-exempt organizations like GuideStone, it may increase costs for prescription drug plans through medical vendors and pharmacy benefit managers (PBM) as their books of business shrink. It may also increase costs that PBMs charge for administration of the RDS.

  What this means for you: TBD

  

• Itemized Deduction for Medical Expenses Threshold Increases

  Who this affects: Participants

  Summary: The income threshold for claiming the itemized deduction for medical expenses will increase from 7.5% to 10% of adjusted gross income. However, individuals over 65 will be able to claim the itemized deduction for medical expenses equal to at least 7.5% of adjusted gross income through 2016.

  What this means for you: TBD

  

• Hospital Insurance Tax for High Earners

  Who this affects: Participants

  Summary: The hospital insurance (HI) tax rate (the Medicare portion of FICA; currently 1.45% of income) will increase by 0.9% (to 2.35%) for taxpayers earning over $200,000 ($250,000 for married couples filing jointly). The HI tax rate will remain 1.45% for other taxpayers. In addition, in the case of taxpayers earning over $200,000 ($250,000 for joint returns), unearned income (e.g., dividends, interest, royalties, etc.) will be subject to a 3.8% HI tax.

  What this means for you: TBD

  
• 2014

  Waiting Periods

  Who this affects: Everyone

  Summary: The healthcare reform law prohibits group health plans and employers from imposing excessive waiting periods before an individual is eligible for coverage under the plan. A waiting period is excessive if it exceeds 90 days. While GuideStone does not impose waiting periods under its plans, employers are free to do so, but will need to follow the healthcare reform law restrictions.

  What this means for you: TBD

  

• New Health Insurance Regulations

  Who this affects: Everyone

  Summary: Insurance companies in the individual market will be prohibited from refusing to sell or renew policies due to an individual's health status, or excluding coverage for pre-existing health conditions. Insurance companies will be restricted in the amount they can vary premium rates due to health status, gender or other factors. Premiums will be allowed to vary based only on age (by no more than 3 to 1), geography, family size and tobacco use.

  What this means for you: Will employers be required to provide health insurance?  I was previously declined by GuideStone. Can I get GuideStone coverage now?

  

• Health Insurance Exchanges

  Who this affects: Everyone

  Summary: Each state (or states together) is supposed to open a Health Insurance Exchange where small employers and individuals who do not have minimum essential coverage through an employer or the government and small employers can comparison shop among an array of standardized health plans. The Exchanges are intended to facilitate enrollment and administer tax credits (affordability subsidies) so that people of all incomes can obtain affordable coverage.

  What this means for you: I was previously declined by GuideStone. Can I get GuideStone coverage now?

  

• Individual Mandate

  Who this affects: Everyone

  Summary: Subject to certain exceptions, individuals will be required to obtain acceptable health insurance coverage (from an employer, an Exchange, Medicare or Medicaid) or else pay an excise tax equal to the greater of $95 or 1% of income in 2014; $325 or 2% of income in 2015; $695 or 2.5% of income in 2016. Families will pay half the amount for each uncovered child up to a maximum of $2,250 per family. After 2016, these dollar amounts will be indexed to inflation. Individuals are exempt from the excise tax if they cannot afford coverage, their household income is below the threshold for filing income tax returns, or they are unable to obtain coverage as a result of a hardship.

  What this means for you: TBD

  

• Health Care Affordability Tax Credits

  Who this affects: Participants

  Summary: Premium tax credits will become available through the Exchange so that individuals can obtain affordable coverage. Credits will be available on a sliding scale for people with incomes below 400% of federal poverty level (approximately $43,000 for an individual; $88,000 for a family of four) who are not eligible for minimum essential coverage from an employer or the government. The credits apply to both premiums and cost-sharing (deductibles and coinsurance) in order to limit out-of-pocket expenses for low-and middle-income families.

  What this means for you: TBD

  

• Employer Penalties

  Who this affects: Employers

  Summary: The healthcare reform law requires employers with 50 or more full-time employees to offer minimum essential health coverage to their full-time employees (and their dependents) or pay a penalty. If an employer does not provide minimum essential health coverage or the employer provides unaffordable health coverage, then the employer will be subject to a penalty if even one of its employees receives a health care tax credit. This is called a "free-rider penalty." Small employers (those with fewer than 50 full-time employees) are exempt from these penalties. More guidance is expected prior to the effective date of this provision to clarify how this will apply to healthcare plans and GuideStone will then determine the impact to its plans.

  What this means for you: TBD

  

• Reporting Requirements

  Who this affects: Employers

  Summary: Each employer with 50 or more full-time employees will be required to file an annual report with the Secretary of Treasury certifying whether it offers minimum essential coverage to full-time employees. The report must also include certain information about the employer's full-time employees and health coverage, including any required waiting period for health coverage, the number of full-time employees during each month, and the name, address and Social Security number of each full-time employee. We expect that more guidance on these new reporting requirements will be forthcoming.

  What this means for you: TBD

  

• Free Choice Vouchers

  Who this affects: Everyone

  Summary: Employers must offer certain lower paid employees a "free-choice voucher" if the coverage provided under the employer's health plan is unaffordable. The amount of the free choice is equal to the employer contribution for coverage under the employer's health plan. The employee can use this voucher to purchase coverage on an Exchange (and keep the remainder if less expensive coverage is purchased through the Exchange). The employer will not incur a free-rider penalty for not offering minimum essential coverage (described above) for employees receiving free-choice vouchers.

  What this means for you: TBD

  

• Wellness Incentives

  Who this affects: Employers

  Summary: The limit on wellness program incentives under HIPAA will increase from 20% to 30% of total cost of coverage.

  What this means for you: TBD

  

• Medicaid Eligibility Increases

  Who this affects: Participants

  Summary: Medicaid eligibility in all states will be expanded to cover all non-elderly individuals whose income is 133% of federal poverty level. States will receive increased federal funding to cover these new populations.

  What this means for you: TBD

  

• Small Business Tax Credit

  Who this affects: Employers

  Summary: The small business tax credit for qualified small employers will continue until 2016, but only for small employers that provide coverage to their employees through the Exchanges.

  What this means for you: TBD

  

• Minimum Benefits Package

  Who this affects: Participants

  Summary: The Department of Health and Human Services will release a package of essential standard benefits for policies sold on the Health Insurance Exchange as well as in individual and small-group plans. There will be a choice between tiers (gold, silver and bronze) which vary by cost-sharing.

  What this means for you: TBD

  
• 2018

  Excise Tax on High-Cost Plans Begin - Cadillac Plan Tax

  Who this affects: Everyone

  Who this affects: A 40% excise tax will be imposed on certain high-cost employer-sponsored health plans (i.e. "Cadillac" plans) to the extent that the annual cost for an employee exceeds a threshold amount. Stand-alone vision and dental coverage is excluded from the cost calculation.

  Plans with higher-than-average costs, because of the age or gender demographics of their participants, may adjust the value of their coverage using the age and gender demographics of a national risk pool. Because this provision is not effective until 2018, we expect additional guidance to be issued in the future.

  What this means for you: What is the definition of the Cadillac plan?