Posts Categorized: Health Benefits

JCEB Health and Welfare Annual Meeting

in Affordable Care Act, Health Benefits

The JCEB Health and Welfare annual meeting just concluded in DC today.  We had some great discussions, which I will pass on in the coming days.  However, I want to thank all my colleagues in CMS, EBSA, HHS, IRS and Treasury for their participation.  We all appreciated the time you took from your busy schedules to attend.  The information you shared was very helpful.

HIPAA Privacy Update

in Health Benefits, HIPAA Privacy & Security

 Many of you have inquired about the status of the final HIPAA regulations under HITECH.  Recently, the head of OCR announced that the final rule could be out by the end of the year, but may be pushed to early 2012.  The package will include a number of outstanding regulation projects, including the final HITECH regulations, the final HIPAA enforcement rule, the final breach notification rule and the final GINA rule.  Once the final package is released, covered entities will have 180 days to comply with the new notice, policy and procedure and other requirements.  However, changes to existing business… Continue Reading

Summary of Benefits and Coverage (SBC)

in Affordable Care Act, Health Benefits

This morning the agencies released proposed regulations that establish the requirement to distribute a uniform explanation of coverage.  This uniform document is being referred to as the “SBC” or Summary of Benefits and Coverage.  A link to the press release and a link to the SBC template form is provided below.  The agencies also released over 30 pages of “instructions” on how to complete the SBC.  Because these are proposed regulations, changes in the regulations and in the draft template are possible when the regulations are finalized.  Employers should consider submitting comments in appropriate situations. The SBC is a standard… Continue Reading

EBSA Electronic Distribution Rules

in Health Benefits, Retiree Benefits, Welfare Benefits

Today, EBSA posted all of the public comments received with respect to electronic distribution of benefit plan information. There are many great comments in this listing, including Kilpatrick’s comments listed as Number 32.  Although DOL is still reviewing the comments, DOL is apparently focusing on other plan materials (such as 401k statements for example) that can be delivered electronically, rather than SPDs and SMMs.  It’s unclear whether this is because DOL already has decided to adopt separate rules depending on the type of document to be transmitted.  DOL has said that proposed regulations could be issued by the end of… Continue Reading