Posts Tagged: SBC

Updated SBC Guidance

in Affordable Care Act

As I noted during Friday’s post, the agencies announced additional SBC guidance will be forthcoming.  Ever coy about release dates, the agencies did not happen to say that the release date was right after our Friday meeting!  DOL released the updated guidance in the form of additional FAQs and updated SBC templates.  One of the more shocking issues addressed in this new guidance is relaxed electronic disclosure requirements.  Specifically, the updated guidance provides that SBCs may be provided electronically to participants and beneficiaries in connection with their online enrollment or online renewal of coverage under the plan. SBCs also may… Continue Reading

ABA Section of Taxation Meeting

in Affordable Care Act, Health Benefits

This morning we held our annual May meeting for the health and welfare subcommittee of the Section of Tax.  I want to thank all the IRS and Treasury people that attended the meeting – at one point I counted at least eight in attendance.  We discussed the usual suspects – SBCs, SPDs, PCOR fees, MEWAs – and a few other acronyms.  The most interesting item was by far the SBC rules.   There will be a lot of issues and headaches to work out for SBCs this summer and fall.  In this regard, there is an unofficial rumor that additional SBC… Continue Reading

Additional SBC Guidance

in Affordable Care Act

This afternoon the agencies released additional SBC guidance aimed at easing the compliance burden for group health plans.  Some of the key highlights of this new guidance include:   1.  Good Faith Standard.  Rather than delaying the requirements for one year, the agencies adopted a good faith compliance standard for 2013.   2.  Dependent Tiers.  As noted in our prior Legal Alert, the final regulations were unclear regarding whether an SBC was required for each dependent tier.  The new guidance confirmed that a separate SBC is not required for each dependent tier.   3.  SBCs Distributed with Open Enrollment Materials. … Continue Reading

Final SBC Rules – Alert

in Affordable Care Act

We have posted our Legal Alert on the Kilpatrick site regarding the final SBC rules.  Appended below is a direct link. Final Summary of Benefits and Coverage Rules – A Rocky Compliance Road for Employer Plans

ABA Section of Tax Meeting

in Affordable Care Act

I recently spoke at the ABA Section of Tax meeting in San Diego this past weekend.  Besides having beautiful weather, we had some great conversations regarding the final SBC regulations, the employer penalty under 4980H, Form W-2s and the changes in the San Francisco health coverage law.  I want to thank all the governmental speakers that attended, and we certainly appreciate your informal comments regarding these new rules.  Our next meeting is in May in DC, which is traditionally our best attended meeting from both the practitioner and the government side.