Article courtesy of Payne Financial Group, January 2012.

Health care reform continues to bring changes for employers and health plans. Here's what employers need to know for 2012.

• - Determine whether you have a grandfathered plan, and whether your plan will maintain that status in 2012. If you make certain plan changes, the plan is no longer grandfathered. If you have a non-grandfathered plan, it must comply with various health care reform provisions.
• - The deadline to provide a Summary of Benefits and Coverage (SBC) was extended until final regulations are issued.

The former proposed deadline was March 23, 2012. It is unknown when final regulations will be issued.

• - Once the SBC requirement becomes effective, plans must provide 60 days' notice of any material modifications to the plan that are not related to renewals of coverage.
• - For non-grandfathered plans starting on or after Aug. 1, 2012, certain women's preventive health services must be covered with no cost sharing.
• - Fully insured plans may receive rebates in August 2012 if they qualify for one under the new medical loss ratio rules. The rebates must be used for the benefit of plan members, which may include reducing enrollees' premium payments.
• - Beginning with the 2012 tax year, employers who issue 250 or more W-2 Forms must report the aggregate cost of employer-sponsored group health coverage on employees' W-2 Forms. The cost must be reported beginning with the 2012 W-2 Forms, which are issued January 2013. The requirement is optional for smaller employers until further guidance is issued.
• - If your state previously required you to impute income for covering dependents up to age 26, check for changes to your state's tax code. All states should now conform to federal tax law, which permits this coverage to be provided tax-free.
• - Self-funded plans must pay a $1 per covered life fee for comparative effectiveness research. Fees are effective for the first renewal after Oct. 1, 2012.
• - Small employers that qualify for the tax credit provided by health care reform can claim it by filing Form 8941 with their annual tax filings. Employers with fewer than 25 employees and who pay average annual wages of less than $50,000 generally qualify.

There were many developments with the health care reform law in 2011, including:

• - The W-2 reporting requirement was delayed for small employers (filing fewer than 250 Forms W-2). Larger employers must follow the rule starting with 2012 Forms W-2.
• - The 1099 reporting requirement was repealed by Congress.
• - Additional women's preventive care guidelines were issued, effective Aug. 1, 2012.
• - Proposed guidance was announced about the summary of benefits and coverage requirement. Plans need not comply with this provision until final regulations are issued.
• - New guidance was issued about the required claims and appeals process, including updated model notices.
• - The Early Retirement Reinsurance Program is no longer accepting new applications for the program.
• - New guidance was issued on the annual limit waiver program. New applications are no longer accepted, but waivers already granted will apply until the first plan year after Jan. 1, 2014 (reapplication not required).
• - HHS issued a final regulation aimed at controlling large health insurance premium increases.
• - HHS issued final regulations about the medical loss ratio rule. The regulations are effective Jan. 1, 2012.
• - Proposed regulations were released for state health insurance exchanges.
• - The free choice voucher provision was repealed by Congress.
• - The CLASS Program was suspended.
• - Reform law was challenged in various federal courts, and the U.S. Supreme Court announced it would review the law's constitutionality in 2012.