On August 22, 2011, the Departments of Health and Human Services, Labor and Treasury issued a proposed rule under the Patient Protection and Affordable Care Act (“PPACA” or the “Act”) that mandates group health plans and health insurance issuers to provide participants with a uniform summary of benefits and coverage (“Summary”). The effective date for the proposed rule is presently March 23, 2012. On November 17, 2011, the Department of Health and Human Services posted a statement on its website advising that the proposed rule may be delayed.
It appears that the anticipated delay is in response to a number of comments by insurance issuers and employer groups which expressed concerns about the proposed rule, including concerns that there will not be enough time to implement the rule. The website posting included a statement indicating that once the final rule is issued it will include an effective date that gives insurance issuers and group health plans a sufficient amount of time to comply with the rule. It further indicated that insurers and group health plans will not be required to comply with the rule until the final regulations are issued.
If you have any questions concerning this matter or any other issues involving employee benefits, please feel free to contact us.