Department of Labor–ACA Summary Plan Description Guidance

There has been a great deal of conversation and interest from brokers, insurers and employers regarding the highly touted Summary of Benefits and Coverage paperwork that employers were required to start distributing on March 23, 2012 (according to PPACA).  The closer we got to March, the more concern there was in the ranks as everyone needed direction on how/what they needed to do in order to comply.  What were the documents to look like (i.e., what were the required contents)?  What was the timeframe that they needed to be distributed?

On Thursday, November 17th, the U.S. Department of Labor quietly posted a FAQ on their website which brings a great deal of clarity to this requirement.  It appears that the deadline has been delayed indefinitely until public comment and final regulations could be concluded.  Most pleasing, of course, instead of the Obama administration’s prior track record of making many provisions of various laws RETRO thus forcing carriers and brokers great expense in going back to clients that were newly eligible for the requirement (like the COBRA subsidies contained in the original Stimulus Package [and subsequent extension of the program] and the creation of the term ‘grandfathering’ in the ACA legislation effective the date of the passage of the law even though guidance/regulations that were required to administer that provision of the law did not come out for several months afterwards), they eluded to the fact that once the regulations were created, they would give the carriers lead time to implement the requirements.  Here is a link to the official release (http://www.dol.gov/ebsa/faqs/faq-aca7.html#pagecontent).  We wanted to get this note of positive news out to the field as soon as it became available.

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