Health Care Reform Summary of Benefits Mandate Delayed

The Affordable Care Act health reform mandate requiring health plans to provide a Summary of Benefits to workers required employers to distribute these summaries by March 23, 2012. 

We're not sure if the mandate for summaries is covered in this chart or not but...

The Departments of Labor, Treasury and Health and Human Services have released  an FAQ document  stating that “until final regulations are issued and applicable, plans and issuers are not required to comply with PHS Act section 2715.”

In other words- compliance with the Summary of Benefits mandate will not be required until they develop a date in the final regulation. (We’re not sure  exactly when this FAQ was released, the Department of Labor doesn’t seem to date their web postings consistently.)

And they gave no indication as to when a final rule would be published.

Here’s what they did have to say:

The Departments received many comments on the proposed regulations and templates and intend to issue, as soon as possible, final regulations that take into account these comments and other stakeholder feedback.

PHS Act section 2715 provides that group health plans and health insurance issuers shall provide the Summary of Benefits and Coverage and Uniform Glossary pursuant to standards developed by the Departments.  Accordingly, until final regulations are issued and applicable, plans and issuers are not required to comply with PHS Act section 2715.

It is anticipated that the Departments’ final regulations, once issued, will include an applicability date that gives group health plans and health insurance issuers sufficient time to comply.”

Chart

Chart as PDF 

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