state plan. before beginning the process of applying for an innovation waiver, states are required to organize "sufficient" opportunities for public commentary and meaningful feedback of the proposed system. to qualify for the waiver, the state plan must provide insurance at least as comprehensive and as affordable as that required by the aca, must cover at least as many residents as the aca plan would, and cannot increase the federal deficit. the coverage must continue to meet the consumer protection requirements of the aca, such as the prohibition on increasing premiums because of pre-existing conditions. a bipartisan bill sponsored by senators ron wyden and scott brown, and supported by president obama, proposed making waivers available in 2014 rather than 2017, so that, for example, states that wish to implement an alternative plan need not set up an insurance exchange only to dismantle it a short time later. in april 2011, vermont announced its intention to pursue a waiver to implement a single-payer health care system; vermont dropped the plans in december 2014. in september 2011, montana announced it would also be seeking a waiver to set up its own single-payer system. in september 2015, hawaii became the first state to formally post a draft of the section 1332 waiver, which proposed a state-level single-payer healthcare system. the draft requested an allowance to forgo several sections of the affordable care act in conflict with the existing state healthcare system established in 1974, the hawaii prepaid health care act (also known as prepaid). prepaid enforces employer mandated health insurance similar to the aca's provisions, but its regulations are more stringent, creating challenges to their pre-existing infrastructure. massachusetts, vermont, and california have also filed state innovation waivers within 2015-2016. like hawaii, massachusetts and vermont proposed drafts seeking exceptions on the basis of pre-existing employer coverage mandates, while california's waiver sought sources of coverage for undocumented immigrants. there are a number of other states that have shown an interest in pursuing innovation waivers in the future. many of these states (such as arkansas and kentucky) are primarily focused on finding novel approaches to utilize current medicaid funding. states may allow large employers and multi-employer health plans to purchase coverage in the health insurance exchange. the two federally regulated "multi-state plans" (msps) that began being phased into state health insurance exchanges on january 1, 2014, become available in every state. the threshold for the itemized medical expense deduction increases from 7.5% to 10% of agi for all taxpayers. this ends the 3-year delay for taxpayers over age 65. (delayed until 2019 by the tax cuts and jobs act of 2017) effective january 1, 2018 a 40% excise tax on high cost ("cadillac") insurance plans is introduced. the tax (as amended by the reconciliation bill) is on insurance premiums in excess of $27,500 (family plans) and $10,200 (individual plans), and it is increased to $30,950 (family) and $11,850 (individual) for retirees and employees in high risk professions. the dollar thresholds are indexed with inflation; employers with higher costs on account of the age or gender demographics of their employees may value their coverage using the age and gender demographics of a national risk pool. (postponed until january 1, 2020) all health insurance plans must cover approved preventive care and checkups without co-payment. this ends the previous exemption for "grandfathered" health plans that were in existence prior to the passage of the aca. effective january 1, 2019 medicaid extends coverage to former foster care youths who were in foster care for at least six months and are under 25 years old. the increase in the threshold for the itemized medical expense deduction from 7.5% to 10% of agi (originally scheduled to take effect on january 1, 2017) goes into effect (per the tax cuts and jobs act of 2017). the repeal of the "individual mandate" by the tax cuts and jobs act of 2017 goes into effect, reducing the tax penalty to zero. effective january 1, 2020 the medicare part d coverage gap (commonly called the "donut hole") will be completely phased out and hence closed. the "cadillac tax" (originally scheduled to take effect on january 1, 2018) will go into effect. temporary waivers during implementation, 2010-2011 during the implementation of the law, there were interim regulations put in place for a specific type of employer-funded insurance, the so-called "mini-med" or limited-benefit plans, which are low-cost to employers who buy them for their employees, but cap coverage at a very low level. the waivers allowed employers to temporarily avoid the regulations ending annual and lifetime limits on coverage, and were put in place to encourage employers and insurers offering mini-med plans not to withdraw medical coverage before those regulations come into force, by which time small employers and individuals will be able to buy non-capped coverage through the exchanges. employers were only granted a waiver if they could show that complying with the limit would mean a significant decrease in employees' benefits coverage or a significant increase in employees' premiums. by january 26, 2011, hhs said it had granted a total of 733 waivers for 2011, covering 2.1 million people, or about 1% of the privately insured population. in june 2011, the obama administration announced that all applications for new waivers and renewals of existing ones had to be filed by september 22 of that year, and no new waivers would be approved after this date. the limited-benefit plans were sometimes offered to low-paid and part-time workers, for example in fast food restaurants or purchased direct from an insurer. most company-provided health insurance policies starting on or after september 23, 2010, and before september 23, 2011, may not set an annual coverage cap lower than $750,000, a lower limit that is raised in stages until 2014, by which time no insurance caps are allowed at all. by 2014, no health insurance, whether sold in the individual or group market, will be allowed to place an annual cap on coverage. among those receiving waivers were employers, large insurers, such as aetna and cigna, and union plans covering about one million employees. mcdonald's, one of the employers that received a waiver, has 30,000 hourly employees whose plans have annual caps of $10,000. the waivers are issued for one year and can be reapplied for. referring to the adjustments as "a balancing act", nancy-ann deparle, director of the office of health reform at the white house, said, "the president wants to have a smooth glide path to 2014." delays on july 2, 2013, the obama administration announced on the treasury department's website that it would delay the employer mandate for one year, under proposed regulations reg-138006-12 until 2015. in the statement, the administration said that they were delaying implementation in order to meet two goals: "first, it will allow us to consider ways to simplify the new reporting requirements consistent with the law. second, it will provide time to adapt health coverage and reporting systems while employers are moving toward making health coverage affordable and accessible for their employees." the announcement was met with strong criticism by some who claimed that the authority to delay the implementation of the law lay with congress. senate minority leader mitch mcconnell argued that president obama's authorization to delay the provision exceeded the limits of his executive power. house republicans brought two bills to a vote to draw attention to the issue: the authority for mandate delay act; and the fairness for american families act, which would apply the same delay to the individual mandate, arguing that the individual mandate should be treated the same way – an action which the obama administration opposes. constitutional scholar simon lazarus countered critics, saying that the delay was a lawful discretion of executive power: "in effect, the administration explains the delay as a sensible adjustment to phase-in enforcement, not a refusal to enforce… to be sure, the federal administrative procedure act authorizes federal courts to compel agencies to initiate statutorily required actions that have been 'unreasonably delayed.' but courts have found delays to be unreasonable only in rare cases where, unlike this one, inaction had lasted for several years, and the recalcitrant agency could offer neither a persuasive excuse nor a credible end to its dithering." critics of the house republicans' comparison of the employer and individual mandate also pointed out that the two provisions are qualitatively different. in august, another provision was delayed for a year: the premium caps on group plans. this was to give employers time to arrange new accounting systems for the premium caps, but the caps are still planned to take effect on schedule for insurance plans on the exchanges. on 10 february 2014, the treasury department issued treasury decision 9655, which are final regulation, that it would delay the employer mandate until 2016 for employers with 50 to 99 workers. the treasury decision 9655 modifies proposed regulations reg-138006-12.