8/25/11

Labor and Employment Alert: 200+ Pages of Guidance on How to Construct a 4-Page Summary of Benefits and Coverage...

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Attorneys & Professionals

The long awaited guidance on the "four page summary" was finally released on August 17, well after the statutory deadline of March 23, 2011. In two releases that exceed 200 pages, the federal Departments (IRS, DOL and HHS) described the content, format, and distribution rules for the 4-page notice, to be known as the Summary of Benefits and Coverage or "SBC." However, much of the discussion is focused on insured products, and there are significant gaps for employer-sponsored group health plans. The Departments have requested comments on a number of those gaps so we can expect further guidance.

Click below to learn more about the summary.