The Patient Protection and Affordable Care Act: Final Regulations on Summary of Benefits and Coverage Requirement for Group Health Plans

The Departments of the Treasury, Labor, and Health and Human Services have issued joint final regulations implementing the new disclosure requirement under the Patient Protection and Affordable Care Act (the “Affordable Care Act”) for group health plans to provide participants a four-page uniform summary of benefits and coverage (“SBC”). The content and format of the new summary is strictly prescribed by the Affordable Care Act, the final regulations, and the agencies’ supplemental guidance issued simultaneously with the final regulations. Given the complexity of the content and format requirements for SBCs, group health plan sponsors must take immediate steps to prepare SBCs that conform to the final regulations for timely distribution
to plan participants.

This disclosure requirement is in addition to the existing summary plan description requirement applicable to group health plans under the Employee Retirement Income Security Act (“ERISA”). The new SBCs must be on hand to provide to participants during any open enrollment period beginning on or after September 23, 2012, and to provide to other new participants who enroll in a plan other than through open enrollment (e.g., mid-year hires) in the first plan year beginning on or after September 23, 2012.

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