Now that the U.S. Supreme Court has largely upheld the key provisions of the Patient Protection and Affordable Care Act, several deadlines are approaching in the near term. Employers need to focus and prepare to comply with these deadlines, even in an uncertain political climate.

The major deadlines that employers face for the remainder of 2012 with respect to their employer-sponsored group health plans are as follows:

Deadline Date




August 1

Medical Loss Rate Rebates: Have procedures in place to handle any rebates received from insurer in accordance with rules for distribution.


August 1

Preventative Health Services for Women: Non-grandfathered group health plans must provide recommended preventative health services without cost-sharing and adjust services covered in accordance with changes to recommended preventative service guidelines.


September 23

Summary of Benefits and Coverage: Self-insured plans and insurance issuers (or plans for which they provide coverage) must supply a summary of benefits and coverage explanation to participants and beneficiaries in addition to the summary plan description.

December 31


Annual Limits: Plans that choose to extend waivers of restricted limits must resubmit application information.


Upon Issuance of Guidance

Quality of Care Reporting: If guidance is issued soon, non-grandfathered plans may need to disclose (during their fall 2012 open enrollment for 2013) information about plan or coverage benefits and health care provider reimbursement structures.


Upon Issuance of Guidance

Nondiscrimination Rules: If guidance is issued soon regarding prohibition of non-grandfathered insured plans from discrimination in favor of highly compensated employees, plans must comply for plan years beginning a specified period after issuance of guidance.

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