Rain Delay – Postponing Play (or Pay)

By Ron E. Peck, Esq. Sr. VP & General Counsel – The Phia Group, LLC / Phia Group Consulting, LLC A Delay In Play (or Pay) – The News Isn’t As Good As You May Think The Obama administration announced that it is postponing the requirement that employers provide employees robust, aff
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Employee Benefits-DOL Says That SBCs Need Not Be Provided For Medicare Advantage Plans

  In FAQ Part X on the Affordable Care Act, the Department of Labor (the “DOL”) says that, if one of the benefit packages in a group health plan is a Medicare Advantage plan, the employer is not required to provide a summary of benefits and coverage (an “SBC”) for that package. &
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Plan Sponsors Working Diligently and in Good Faith on the Summary of Benefits and Coverage Will Not Face Penalties During the First Year

On May 11, 2012, the Departments of Labor, Health and Human Services and Treasury issued answers to Frequently Asked Questions (FAQs) about the new Summary of Benefits and Coverage (SBC) requirements of the Affordable Care Act.1 The FAQs are the ninth set of questions and answers abou
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EBSA Loosens Health Reform Rules for SBC Delivery, Stays Enforcement

A set of safe harbors related to the enforcement of summaries of benefits and coverage (SBCs), which insurers and plan sponsors must distribute as part of health care reform, was issued May 11 by the U.S. Department of Labor and the Employee Benefits Security Administration.   Re
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DOL Releases New Guidance on SBC Preparation and Delivery

DOL Releases New Guidance on SBC Preparation and Delivery The Department of Labor released a set of “Frequently Asked Questions” to clarify some of the basic aspects of preparing and providing the new Summary of Benefits and Coverage. Notable in the release is the announce
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Summaries of Benefits and Coverage Due This Fall

Final regulations provide detail on the format, content, and delivery standards group health plan sponsors and insurers must follow when issuing this information. As they prepare for open enrollment this fall, group health plan sponsors and insurers have a lot of work to do to make su
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Health Care Plan Summary of Benefits and Coverage Distribution Deadline Quickly Approaching for Employers

Employers who maintain health plans may recall from our prior blogs (see “Health Care Plan Annual Enrollment Triage: The Summary of Benefits and Coverage Standards Have Not Been Issued Yet and May Just Have to Wait“ and ”Health Care Plan Summary of Benefits and Coverage: Still No Fina
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Summary of Benefits and Coverage Disclosure Requirements

Recently issued final regulations and related guidance clarify the requirement under the Patient Protection and Affordable Care Act that group health plans and health insurance issuers provide a summary of benefits and coverage and a uniform glossary. The guidance includes final regul
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Added Guidance on Summaries of Benefits and Coverage

The three agencies responsible for issuing guidance on the Affordable Care Act (ACA)—the U.S. Departments of Labor, Treasury, and Health and Human Services—have issued a new set of FAQs (frequently asked questions and answers) on the requirement to furnish summaries of benefits and co
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Summary of Benefit Coverage Rules – The Devil is in the Details

During the February 28, 2012 ALI-ABA Video Broadcast program on Health Plans some representatives from the government provided us with their personal insights on how the Summary of Benefits and Coverage (“SBC”) rules and templates should operate. Earlier this week the DoL posted FAQ V
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