Health care reform has expanded ERISA’s disclosure requirement by requiring that “summary of benefits and coverage” (SBC) be provided to health plan participants and beneficiaries. The summary must accurately describe the benefits and coverage under the applicable plan and the requirement is in addition to ERISA’s SPD and SMM requirements.
When Must the SBC Be Distributed?
Beginning with the first open enrollment period beginning on or after September 23, 2012 for participants and beneficiaries enrolling or re-enrolling through open enrollment. For individuals enrolling other than through open enrollment (newly eligible individuals or special enrollees), the requirement applies beginning on the first day of the first plan year that begins on or after September 23, 2012. For calendar-year plans, this means that SBCs will first be required during open enrollment in 2012 for the 2013 plan year.
The SBC requirement applies to so-called “grandfathered” health plans under Health Care Reform. It is not one of the requirements from which those existing group health plans and health coverage were excused.
What Methods of Distribution?
The SBC may be provided in paper form or electronically to participants and beneficiaries covered by the plan.
For participants and beneficiaries who are eligible but not enrolled, the SBC may be provided electronically if the format is readilly accessible and a paper form is provided free of charge upon request. For these participants and beneficiaries only, the SBC may be provided via Internet posting if the individuals are notified in paper form (such as a postcard) or via email that the documents are available on the Internet.
Which Plans Are Required to Provide the SBC?
The SBC requirement applies to group health plans both insured and self-funded but not to certain “excepted benefits”. Other requirements do apply, please refer to the SBC guidelines for more details.
For more details concerning the specifics of the regulation click here Summary of Benefits and Coverage.
If you have any questions, please contact your M.F. Irvine Representative.
Source: U.S. Department of Health & Human Services, www.hhs.gov; Thomson Reuters/EBIA
Note: Employers who are required to file fewer than 250 2011 W-2 Forms are not required to report this information. Only those employers with greater than 250 W-2’s in 2011 must comply.
Below are some of the highlights of the guidance:
Purpose
Effective Date
Scope of Health Plan
Amount Reported
How M.F. Irvine Can Assist
For existing M.F. Irvine Benefit Administration clients, M.F. Irvine Corporate Solutions will be providing a special report at the end of the 2012 calendar year (early January 2013). This report will include the total value of the Medical Plan (i.e., the COBRA applicable premium minus the 2%) for active and terminated employees for the 2012 calendar year.
If you have any questions, please contact your M.F. Irvine Representative.
Source: IRS Notice 2011-28
]]>
]]>
To hear Michael Irvine’s interview click here http://www.executiveleadersradio.com/irvine-michael-1960.aspx
]]>Airing Schedule:
WIFI 1460AM - Friday 2pm-3pm
WSNJ1240AM - Monday 1pm-2pm
WCHE 1520AM - Sunday 1pm-2pm Executive Leaders Radio can be found on the following podcast directories:
]]>