The Departments of Labor, Treasury and Health and Human Service (the "Agencies") recently released final regulations and related guidance to employers in connection with the "Summary of Benefits and Coverage" ("SBC") required to be provided to health plan participants under the Patient Protection and Affordable Care Act of 2010 ("PPACA").
Starting on September 23, 2012 (generally the first day of the first open enrollment period that begins on or after September 23, 2012), employers and insurers are required to provide succinct summaries of their health plan benefits (no more than four double-sided pages in 12-point or larger font) in a standardized form that must include a glossary of insurance and medical terms – featuring generic definitions, not the plan-specific ones that would appear in a summary plan description (SPD) – as well as illustrations of how the particular plan would generally provide benefits for people in standard medical situations. The SBC requirements apply to group health plans (but not HIPAA-excepted benefits such as certain dental, vision, and health FSA arrangements), regardless of grandfathered status.
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