Details are emerging about the deadlines for implementation of the various requirements for employers. Employers are not required to provide group health insurance to employees, but not offering coverage comes with a price, depending on employer size. The most comprehensive list of effective dates is posted on the Clark Hill website.
The first phase begins for qualified small employers to receive a tax credit of up to 35% of their employee health care coverage expenses. A "qualified small employer" is an employer that does not have more than 25 employees with average annual compensation levels not exceeding $50,000. MSAE is still waiting for the release on how nonprofits will receive this credit.
Effective for tax years beginning after December 31, 2010 all employers will be required to report on W-2s the cost of employer sponsored health coverage that is excludable from an employee's gross income and the employer tax deduction for employees who receive Medicate Part D drug subsidies is eliminated.
For employer plans effective for plan years beginning on and after September 23, 2010, group health plans offering dependent coverage must make dependent coverage available for children up to age 26, they are prohibited from discriminating in favor of highly compensated individuals, they are required to disclose the percentage of revenue spent on medical claims and provide a rebate to participants if the group health plan does not spend a minimum of 80% (small group or individual plans) or 85 % (large plans) of its revenue on claims (the requirement to provide a rebate becomes effective January 1, 2011).
More details on this topic will be presented to ORGPRO on Wednesday, July 14.