Last week, the Departments of Treasury, Labor and Health and Human Services issued final regulations regarding the Summary of Benefits and Coverage (“SBC”) Rules under the Affordable Care Act. The final rules are significantly better than the proposed rules. However, many provisions in the final rules are still drafted in terms of individual policies. Converting these rigid rules to the world of employer plans will likely require a suspension of reality in many situations.
The final SBC rules are effective for open enrollment periods that begin on or after September 23, 2012. Thus, for most calendar year plans, the rules will be effective during open enrollment for 2013, which will occur this fall.
Please see the attached Legal Alert for additional details regarding the SBC final rules.
Mark L. Stember
Kilpatrick Townsend & Stockton LLP
Suite 900 | 607 14th Street, NW | Washington, DC 20005-2018
office 202 508 5802 | cell 202 714 5019 | fax 202 585 0018
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