Section 2715 of the Public Health Service Act, which was added by the Patient Protection and Affordable Care Act as amended by the Health Care and Education Reconciliation Act of 2010 (collectively, the “Act”) expands ERISA’s disclosure requirements by requiring group health plans to provide a four-page summary of benefits and coverage (the “SBC”) to applicants and enrollees before enrollment or re-enrollment. All group health plans, including grandfathered plans,[1] will be required to furnish SBCs effective March 23, 2012. Retiree-only and HIPAA-excepted plans, such as stand-alone dental and vision plans, are not subject to this new requirement.

On August 22, 2011, the Departments of Health and Human Services, Labor, and Treasury (the "Departments") jointly issued proposed regulations (the "Regulations") and a proposed SBC template and uniform glossary. The proposed SBC template can be found here. The proposed uniform glossary can be found here.

and links.