Under health care reform, plan participants and beneficiaries must be provided a 4-page summary of benefits and coverage (“SBC”) and uniform glossary. This requirement is effective for open enrollment periods that begin on or after September 23, 2012. For participants and beneficiaries who enroll in group health plan coverage outside of open enrollment (e.g., newly eligible individuals and special enrollees), the SBC must be provided beginning on the first day of the first plan year that begins on or after September 23, 2012. This requirement is an ongoing one and, as open enrollment season approaches, the Departments of Labor, Health and Human Services, and Treasury have issued updated guidance and a revised SBC template that includes some important changes.
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