Delayed Effective Date For Summary Of Benefits And Coverage Requirements

The Patient Protection and Affordable Care Act (PPACA) expanded the disclosure requirements for group health plans and health insurance issuers, mandating that participants and beneficiaries be provided with a four-page summary of benefits and coverage (SBC) for each benefit package offered. The PPACA provided that this disclosure requirement was effective beginning March 23, 2012. (See our November 2011 Employee Benefits Broadcast ( http://tinyurl.com/bt2xwjj) for additional information regarding the SBC requirements.)

On August 22, 2011, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the Departments) issued proposed regulations and templates in connection with the implementation of the SBC requirements. The proposed regulations contained an applicability date of March 23, 2012.