Hall County Government
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Compass
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Regional Vice President of Sales The Retirement Plan Company
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Guest Article
(From the March 26, 2012 issue of Deloitte's Washington Bulletin, a periodic update of legal and regulatory developments relating to Employee Benefits.)
The Department of Labor released a set of "Frequently Asked Questions" to clarify some of the basic aspects of preparing and providing the new Summary of Benefits and Coverage. Notable in the release is the announcement of a "good faith" compliance standard for the first year the SBC requirement is applicable.
Group health plans (and group health issuers) are required to provide participants and beneficiaries with an SBC beginning on the first day of the first open enrollment period that begins on or after September 23, 2012. Final regulations on this new disclosure requirement were issued last month. In response to questions received from the public about the new requirement, the Departments of Labor, Treasury, and Health and Human Services jointly prepared a set of FAQs to provide additional guidance. Among other things, the FAQs explain:
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Further, the FAQs include discussion of SBCs in the context of COBRA, the circumstances that trigger the obligation to provide an SBC (e.g., how the terms "application" and "renewal" apply to self-insured plans), the issuers in the individual market, satisfying the "culturally and linguistically appropriate" requirement, and modifying the prescribed SBC template.
The information in this Washington Bulletin is general in nature only and not intended to provide advice or guidance for specific situations.
If you have any questions or need additional information about articles appearing in this or previous versions of Washington Bulletin, please contact: Robert Davis 202.879.3094, Elizabeth Drigotas 202.879.4985, Mary Jones 202.378.5067, Stephen LaGarde 202.879-5608, Erinn Madden 202.220.2692, Bart Massey 202.220.2104, Tom Pevarnik 202.879.5314, Sandra Rolitsky 202.220.2025, Deborah Walker 202.879.4955. Copyright 2012, Deloitte. |
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