Jenner & Block

Client Alert: Final PPACA Summary of Benefits and Coverage Regulations Issued

The Treasury Department, the Department of Labor, and the Department of Health and Human Services recently issued final regulations on the required Summary of Benefits and Coverage (SBC) and uniform glossary under the Patient Protection and Affordable Care Act (PPACA).  The final regulations delay the effective date of the SBC requirements until (i) the first day of the first open enrollment period that begins on or after September 23, 2012, for participants and beneficiaries who enroll or re-enroll in group health coverage through open enrollment, and (ii) the first day of the first plan year after September 23, 2012 (i.e., January 1, 2013, for calendar year plans), for participants and beneficiaries who enroll in coverage other than through an open enrollment.