Posts Tagged: SBC

Final SBC Regulations

in Affordable Care Act

Final SBC rules were released this morning.  As noted in a prior post, the agencies have delayed the application of the final SBC rules to the first plan year on or after September 23, 2012. Effectively, this means that SBCs must be issued for the 2013 calendar year, as well as new hires and special enrollments beginning January 1, 2013. Although additional clarification may be needed from the agencies, it appears that employers have until December 1, 2012 to issue SBCs effective for the 2013 calendar year. Our team will be preparing an analysis of these rules for distribution next week…. Continue Reading

SBC Requirements Delayed

in Affordable Care Act

A few weeks ago I reported that DOL, IRS and CMS were considering a delay in the Summary of Benefits and Coverage requirements.  Currently, in the proposed regulations, the agencies anticipated an effective date of March 23, 2012.   This evening DOL announced that the effective date of the SBC requirements would be delayed when the final regulations were issued.  However, DOL did not provide what that effective date would be.  Rather, DOL indicated that when the final regulations are released, plans will be given a “sufficient time” to comply.  Based on prior informal conversations, I anticipate the final regulations to be issued in… Continue Reading

SBC Update

in Affordable Care Act

Earlier this week I participated in the annual JCEB health and welfare meeting here in DC.  Many governmental guests were in attendance.  The guests made some employer-favorable comments about the upcoming final SBC rules.  I should stress that these comments are informal comments and nothing will be final until the final regulations are published.  We discussed three key items.   1.  The proposed regulations provided that the SBC rules would be effective March 23, 2012.  It appears that date is likely to be postponed until later in 2012.   2.  The proposed regulations provided that SBC documents would need to be distributed 60 days prior… Continue Reading