Departments Release Additional FAQs on Summary of Benefits Coverage Requirement

On August 7, 2012, the U.S. Departments of Labor, Health and Human Services and the Treasury issued Part X in the set of FAQs addressing implementation of the Patient Protection and Affordable Care Act.  The latest FAQ provides that the Summary of Benefits and Coverage (SBC) does not have to provide for Medicare Advantage benefit packages.  As a reminder, for group health plan coverage, for disclosures concerning participants who enroll or re-enroll through an open enrollment period (including late enrollees and re-enrollees), the SBC must be provided beginning on the first day of the first open enrollment period that begins on or after September 23, 2012.  For disclosures with respect to participants who enroll in coverage other than through an open enrollment period (including individuals who are newly eligible for coverage and special enrollees), the SBC must be provided beginning on the first day of the first plan year that begins on or after September 23, 2012 (i.e., January 1, 2013 for a calendar year plan).  The latest FAQ is available here.