"A significant concern about the current proposal is whether it would require repapering all of the prior disclosures. However, it is unclear from the proposal whether, once finalized, the rule would require that covered service providers furnish the guide to existing plan clients or only when entering into new arrangements for services. Even if service providers are not required to furnish existing clients with a guide right away, they may be required to provide one to existing clients under the annual update requirement."  MORE >>