Archive for February, 2012

CMS Announces 7 CO-OP Loans, Including 1 in Iowa

February 21, 2012

Today CMS  awarded seven loans under the Consumer Oriented & Operated Plan (“CO-OP”) Program.  The CO-OP Program provides low-interest federal loans to qualifying non-profit cooperatives to establish health insurance for cooperative members.  One of the  loans was made to Midwest Members Health, a cooperative sponsored by the Iowa Institute, who applied to offer insurance within Iowa and Nebraska.   More information on the awards  is available at


Summary of Final SBC Rules

February 17, 2012

On Tuesday, the final Summary of Benefits and Coverage rules were posted in the Federal Register.  Employers sponsoring group health plans will have to comply with these rules starting with their first open enrollment period on or after September 23, 2012.  A summary of the final rules is available on the Davis Brown website.

Final Rules Released for Summary of Benefits & Coverage

February 9, 2012

Today the Department of Labor released final regulations implementing the Affordable Care Act’s summary of benefits and coverage (“SBC”) requirement.  The rules require  employers sponsoring group health plans to distribute an SBC to employees and participants in certain situations, such as at open enrollment.  The rules were originally supposed to be effective on March 23, 2012; however, the final rules delay the effective date.  The new effective date is (i)  the first day of the plan’s open enrollment period on or after September 23, 2012 for disclosures required to be provided to re-enrollees or late enrollees; and (ii) the first day of the plan year that begins on or after September 23, 2012 for individuals newly eligible for coverage (such as new hires or special enrollees).  For example, a calendar year plan with an open enrollment period beginning November 15 would need to begin complying with the new regulations on November 15, 2012 for re-enrollees and  late enrollees and January 1, 2013 for newly eligible individuals. 

We will provide a detailed summary of the new rules in the coming days.  A copy of the rules and additional DOL guidance can be accessed at

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