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SBC appearance


Guest VinSzel
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Guest VinSzel

I saw that the final regs on the Summary of Benefits and Coverages rejected the proposal that the document be printed in color. The agencies were concerned that color printing would impose unnecessary costs on plans and, therefore, allowed them to be printed in black & white.

So what about the cost of making double sized prints? The regs and the sub-regulatory guidance are silent. Allowing the SBC to be printed single sided would avoid the same avoidance of unnecessary costs as was noted for color printing.

The only rationale I've seen for any mention of double sided pages involves the content size. The statute mentions a 4 page SBC, which the agencies interpret to be a limitation on content. This is how we get an 8 page SBC form.

What's a small plan with limited resources to do? My feeling is to run the SBC in-house in black and white on 8 single sided pages.

Any other views on this?

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For some employers' health plans, a practical method might be to e-mail the .pdf file.

Although the administrator must furnish paper on a participant's request for it, in my experience almost no one requests it.

For the one or two people who do request a delivery of paper, use a laser printer to print the eight pages double-sided on four sheets.

This method works less efficiently (or even might be counterproductive) if the workforce includes some employees who are not required to use e-mail as a work condition. If the number of employees who are not required to use e-mail is significant, it might be less expensive to do an old-fashioned paper delivery.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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Guest VinSzel

Thanks Peter. For this client, however, we need to do a mass mailing to thousands under the open enrollment/first day of plan year rule and the mass mailing will be in the thousands.

VinSzel

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Thanks. Just so that I learn something, am I right in guessing that the expense differential you mention results because the plan administrator has available in-house a printer that can only print single-sided, but would incur a greater expense to go outside to a printer that can print double-sided?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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