The new rule is designed to discourage companies from making major changes to their insurance plans, but small businesses often change their plans and doing so would jeopardize the "grandfather" status of their plan. At the same time, some experts say there aren't enough safeguards in that rule to prevent insurance companies from raising premiums.
Then there is also the issue of working with states, many of which are still fighting the health care law. The administration has to coordinate with states to establish the temporary high-risk pools that Americans can start enrolling in by July 1. But that deadline could slip as several states remain undecided about how they will proceed forward.
Jennifer Tolbert, a health policy analyst on Medicaid and the uninsured at the Kaiser Family Foundation, said those regulations where HHS has to work with other agencies and states may be delayed, such as medical loss ratio or premium rate reviews, but it's too early to gauge how late they might be.
The National Association of Insurance Commissioners was asked to deliver its recommendations to HHS on medical loss ratio -- the ratio of medical expenses to administrative spending -- by June 1, but the group said last month it won't be able to present its full review until at least July 1.
"Where HHS appears to need more time to develop regulations that avoid any errors or problems or challenges with implementation, it does seem that they are taking extra time to work through some of those issues," Tolbert said. "This is still pretty early on in the process."
Meanwhile, members of Congress are calling for more oversight and Republicans continue to assail the law. Not one GOP member in either the Senate or the House voted for it.
"This is one of the largest pieces of legislation we've ever seen. What we need to do is have an appropriate oversight function to get on the record information as to what's happening with regards to this bill," said Dave Camp, R-Mich., ranking member of the House Ways and Means committee, who has invited HHS Secretary Kathleen Sebelius to testify before the House. "Let's have a public hearing and let's hear how the implementation is going."
Support for the health care law remains divided. In a USA Today/Gallup poll released last week, 49 percent of Americans said they think the plan is a "good thing" while 46 percent said it's bad.
Experts say it's difficult to predict what will happen to the number of uninsured Americans in the immediate future until the administration fully doles out the reforms.
"If the economy remains sluggish and employers continue to be reluctant to hire new workers more people will likely remain uninsured simply because we have a health insurance system which ties health insurance coverage to employment," Tolbert said. "Many of the provisions of the health reform law have yet to take effect. ... It would be impossible to flip a switch and have all of these provisions go into effect within such a short time frame."
June: HHS began mailing out $250 rebate to seniors in the "doughnut hole" -- those who have spent more than $2,830 for prescription drugs. Starting in 2011, older Americans who go past the allotted amount will be given a 50 percent discount on prescription drugs. The bill aims to close the "doughnut hole" completely by 2020, but older Americans will still have to pay for 25 percent of their drugs.