Departments Delay Effective Date For Summary Of Benefits And Coverage

In a Frequently Asked Question ("FAQ"), the Departments of Health & Human Services, Labor, and the Treasury (the "Departments") stated that group health plans are not required to comply with the Summary of Benefits and Coverage and Uniform Glossary requirement until final regulations are issued.

On August 22, 2011, the Departments issued proposed regulations that require group health plans subject to the Patient Protection and Affordable Care Act to furnish a Summary of Benefits and Coverage and Uniform Glossary to plan participants and beneficiaries (the "Summary Requirement").  At that time, the Departments also issued a proposed template for compliance with the Summary Requirement and proposed an effective date of March 23, 2012.