"Plan sponsors should move forward to address the more immediate compliance requirements that are effective in 2012 and 2013.... The responsibility of complying with [the requirement to provide the Summary of Benefits and Coverage (SBC) to participants] ultimately rests with the plan sponsor. Sponsors of insured plans should confirm that the insurer [or third-party administrator, for self-insured plans] is furnishing SBCs in a timely manner and take action if it is not.... [This] may be difficult for plans in which coverage for services such as prescription drugs or mental health benefits has been carved out with a specialty vendor. In those cases, the plan sponsor may need to prepare or coordinate SBCs, incorporating the necessary details."

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