Some of the key points include:
- the effective date of the SBC requirements remains as the first open enrollment period that begins on or after September 23, 2012 and the first plan year that begins on or after that date (for enrollments occuring outside of open enrollment)
- SBCs must be provided at the same time open enrollment materials are distributed
- SBCs may be provided to a participant on behalf of a beneficiary
- SBCs will not be required for different plan features (meaning that different coverage tiers and different plan designs may be included in a single SBC), provided the appearance is understandable
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