Archive for November, 2011

SBC Requirements Likely to Be Postponed

November 18, 2011

The Affordable Care Act requires health insurers and employers sponsoring group health plans to implement a new summary of benefits and coverage notice by March 23, 2012.   Proposed rules implementing the new requirement were issued in August.   Over the last three months employers and insurers have questioned whether it is reasonable to expect compliance with the requirements by March 23, 2012 given final rules have yet to be issued.  Yesterday, the Department of Labor clarified in an FAQ that it does not expect employers or insurers to begin implementing the requirements until final rules are published.  The Department of Labor went on to say that regulators intend to give employers and insurers sufficient time after issuing the final rules to be in compliance.   Given the final rules have yet to be issued, it is likely the compliance date will now be sometime after March 23, 2012. 

A copy of the FAQ can be accessed at


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