Legal Alert: Summary of Benefits and Coverage Requirements Delayed

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Group health plans and health insurance issuers appear to have been granted a reprieve from the March 23, 2012 deadline for complying with the Summary of Benefits and Coverage (SBC) and uniform glossary requirements imposed by the 2010 Patient Protection and Affordable Care Act (PPACA). The federal agencies charged with implementing these requirements recently stated in a series of Frequently Asked Questions (FAQs) that when final regulations are issued, they will "include an applicability date that gives group health plans and health insurance issuers sufficient time to comply." The FAQs also state that until final regulations are issued and applicable, plans and issuers are not required to comply with the SBC and uniform glossary requirements of the PPACA.

On August 22, 2011, the Departments of Health and Human Services (HHS), Labor and Treasury (the Departments) issued proposed regulations and proposed templates in conjunction with the implementation of the SBC and uniform glossary requirements imposed by the PPACA. The proposed regulations set forth standards intended to help consumers better understand the coverage they have and easily compare coverage options.

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