Non-discrimination testing, is going to be very similar to non-discrimination testing for pension and 401k plans but specifically relates to the components of the health insurance coverage versus the employer contributions to the premium cost. The testing will look at items such as deductibles, co-pays, coverage, etc. and ensure that the highly compensated individuals are not receiving a "richer" benefit than the non-highly compensated, similar to retirement plan testing.
All non-discrimination testing related to health care programs will commence in 2014, or at least that is the predicted date at this point in time. Employers, however, should be thinking about requirements that will begin in 2012 for the reporting of employer contributions to health care premiums. This information will have to appear on W-2's given to employees in 2013 for wages, etc., earned in 2012.
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