Under the health care reform enacted in 2010 under the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 (referred to collectively here as “PPACA”) new obligations are imposed on employers and group health plans with respect to the provision of a summary of benefits and coverage and W-2 reporting requirements. Beginning in 2013, moreover, employee salary reduction contributions to health flexible spending arrangements will be limited to $2,500 per year. The following Alert highlights upcoming deadlines with respect to those obligations.

Summary of Benefits and Coverage Requirements -

PPACA requires that a summary of benefits and coverage (“SBC”) be provided to group health plan participants, beneficiaries and eligible enrollees (including COBRA qualified beneficiaries). The SBC is intended to allow individuals to easily compare coverage options across different types of plans and insurance products, and its content is somewhat different than the summary plan description which ERISA plan sponsors are already required to provide.