Patient Protection and Affordable Care Act

The Patient Protection and Affordable Care Act (PPACA) includes a requirement for Plan Administrators to create and distribute a Four-Page Summary of Benefits and Changes document and to provide Notice of Material Modifications.  Interim regulations were issued in August 2011 for this requirement, which is scheduled to go into effect on March 23, 2012.  While the Summary of Benefits and Changes (SBCs) will not need to be issued to existing employees until your group health plan renews, new employees will need to receive the SBC when they become eligible for coverage. In addition, existing employees will be able to request SBCs, and there will be other situations where SBCs will need to be provided during the plan year as outlined in the attached chart.  Also, beginning March 23, 2012, notice must be provided during a plan year when there are material modifications to health plan coverage.  See the attached summary of the interim regulations.  Updates will be provided when the regulations are finalized.