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American Benefits Council Comment Letter to EBSA on Proposed Regs for Summary of Benefits and Coverage (PDF)
American Benefits Council Link to more items from this source
[Opinion]
Mar. 2, 2015
6 pages. "The applicability date in the Proposed Rule does not allow plans and issuers sufficient time to update their internal processes to comply with the Proposed Rule's new requirements or changes in the SBC template.... Subject entities are not under the impression that they are absolved from liability after entering into a contract with a third party.... Additional regulation of such arrangements is simply not necessary ... . Mandating self-insured plans to post [plan] documents online and provide a web address where these documents can be reviewed and obtained would add an extra layer of disclosure that is unnecessary."

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