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Important Information Regarding the PPACA Summary of Benefits and Coverage Requirement

Group health plans, which include HRAs, MERPs, and non-excepted FSAs, must provide a Summary of Benefits and Coverage (SBC) for all eligible plans to all eligible individuals, participants and beneficiaries.

When must the SBC be provided?

During initial enrollment with any written enrollment materials or, if no written enrollment materials, then the first day the individual is eligible to enroll;
During open enrollment for the coverage option in which a participant is currently enrolled;
Upon request, within 7 days; and
At least 60 days prior to a mid-year benefit change
How must the SBC be provided?

In written or electronic form
What is the penalty for noncompliance?

Up to $1,000 per failure
An excise tax of $100 per day per failure
The SBC requirement goes in effect for plans re-enrolling after September 23, 2012.

American Benefits is currently reviewing the requirements to determine if some or all of the required content can be pulled from the plan details, what the best delivery methods are, and if this requirement can be incorporated into the DataPath system. We are currently awaiting further guidance before we can fully determine if and how we could systemize the production of this document.

ECFC is requesting relief from the Department of Labor for HRA and MERP reporting by a delay or a modification of the SBC. We will keep you informed.

For more information, see the DOL site >

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