On February 14, 2012, the Departments of Health and Human Services, Labor and the Treasury (the “Departments”) issued final regulations regarding the summary of benefits and coverage (“SBC”) disclosure requirement imposed by the Patient Protection and Affordable Care Act (“PPACA”) (the “Final Regulations”). A little over one month later, on March 19, 2012, the Departments issued clarifying “frequently asked questions” and answers regarding the implementation of the Final Regulations (the “FAQs”). Together, the Final Regulations and the FAQs provide detailed instructions on how to comply with PPACA’s SBC disclosure requirement. However, plan sponsors and insurance issuers do not have much time to comply with the new SBC disclosure requirement: SBCs must be included in application materials provided to participants and beneficiaries during open enrollment periods that begin on or after September 23, 2012, and must be distributed to new hires and mid-year enrollees in plan years that begin on or after that date.

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