Final Rules Released for Summary of Benefits & Coverage


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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