Effective Date of Summary of Benefits and Coverage Delayed

On November 17, the DOL issued its FAQs About Affordable Care Act Implementation Part VII and Mental Health Parity Act. These FAQs clarify the effective date of the Summary of Benefits and Coverage (“SBC”) required under section 2715 of the Public Health Services Act, as amended by PPACA.

The DOL previously issued proposed regulations regarding the contents of the SBC. The SBC must provide each participant and beneficiary detailed information regarding each health benefit offered under the plan. More information on the who, what, when, where and how of the SBC can be found in our earlier benefits alert.

The proposed regulations provided an effective date of March 23, 2012. The FAQs, however, extend that date until a date to be determined in the final rule. The DOL assures plans and health insurance issuers that the effective date will allow enough time to develop and refine their SBCs to ensure compliance with the final rule.

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