Congress passed the Patient Protection and Affordable Care Act (ACA) in March 2010. Since that time the various federal agencies responsible for implementing the ACA, which include the Internal Revenue Service, as well as Departments of Health and Human Services and Labor, continue to issue regulations on the law. The resources provided below are intended to assist GFOA members with understanding the new law, its implementation challenges, as well as provide recommendations on how to move toward compliance.
Overviews of the ACA Requirements and Timetables
- A Health Care Reform up-to-date, interactive timeline, which lists health care reform rules as they take effect and change year to year
- The Affordable Care Act: What Public Sector Employers Need to Do Now Later This Year and Beyond (to make their plans ACA complaint)
- Internal Revenue Service final regulations implementing the ACA Employer Shared Responsibility Provisions (otherwise known as the play-or-pay employer provisions). The final regulations were accompanied by a fact sheet and a set of Frequently Asked Questions.
The Cadillac Tax
Adopted as part of the ACA, requires that in 2018 plans costing more than $10,200 annually for individuals and $27,500 annually for families be taxed at 40 percent of their costs above these limits.
2015 Update: The omnibus spending bill contains a two-year delay of the implementation of the Cadillac Tax. Thanks in part to an informational campaign conducted by GFOA with a broad coalition of public and private employers, retirement systems, and many other interested groups, repealing the Cadillac tax levied on high-cost employer-sponsored health coverage gained bipartisan and bicameral support throughout the last few months of 2015.
The Cadillac tax, designed originally to begin in 2018, has well over half of the members in both chambers opposing the tax as cosigners on legislation that would fully repeal the tax. On December 3rd, for example, an amendment to repeal the tax easily passed the Senate in a 90-10 vote earlier this month. This vote was merely symbolic, though, as the measure was tacked to the reconciliation bill which the White House vetoed.
While the White House does not support a two-year delay, the President did not veto the omnibus legislation based on the postponement. In so doing, Congress and the President effectively agreed that implementation of the Cadiallac Tax will be postponed to 2020.