Health Care Reform Update 2013

Required Notices to Employees and Dependents 
Please contact your carrier or employment law attorney or trusted benefit advisor if you have questions about these notices. VADA Insurance is here to guide our clients and association members; however, we do not provide legal counsel.

  1. Summary of Benefits and Coverage (SBC). Starting with plan years and open enrollment periods beginning on or after September 23, 2012, provide participants and beneficiaries a  summary of benefits and coverage at specified times during the enrollment process and upon request.Notice of Plan Changes. Additionally, if any material modification is made in any of the terms of the plan or coverage that would affect the content of the SBC, that is not reflected in the most recently provided SBC, and that occurs other than in connection with coverage renewal or reissuance, the plan or issuer must provide notice to enrollees not later than 60 days prior to the effective date of the change.
    1. Note: Insured group health plans may satisfy this requirement if the issuer provides a timely and complete SBC to the participant or beneficiary.
  2. Availability of Health Insurance Exchanges. Beginning March 1, 2013, provide each new employee at the time of hiring (and each current employee no later than March 1) a written notice containing certain information about a Health Insurance Exchange.
    1. Note: The DOL is expected to issue a model notice employers may use to satisfy this requirement along with regulations, which may delay the March 1, 2013 deadline.

Tip: Approach the implementation of these required notifications in the same manner you use to ensure compliance with notifications related to FMLA, COBRA, and Model Notices. Note, there is no “employer size” requirement for these provisions below. All employers/plan sponsors are required to maintain compliance with these provisions.

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