Guidance on Mini Summaries and 60-Day Advance Notice of Changes

Health reform mandates the production and delivery of new documents that are essentially mini-Summary Plan Descriptions (SPD). The Department of Health and Human Services (HHS) and other federal agencies overseeing implementation of health reform have now jointly issued proposed regulations governing this requirement.

  • The regulations introduce a new type of document called the "Summary of Benefits and Coverage" (SBC) and provide detailed rules on what information must be included in the disclosure, including a template, instructions, and a glossary. Our discussion addresses these new rules, as well as electronic disclosure and other practical issues.

  • Employers have been very concerned about a new 60-day advance notice of plan changes, also required by health reform. Fortunately, as explained in our Client Bulletin, the employer or carrier must provide that notice only for off-plan-year/off-anniversary changes.

The new disclosure requirement creates a new paperwork burden on health plan sponsors. HUB is committed to providing you with practical guidance and to working with your carriers and administrators to facilitate compliance to alleviate or mitigate the impact of the rules. The attached Client Bulletin emphasizes issues of particular interest to plan sponsors including the compliance time frame, content and distribution rules, along with other practical considerations for employers as they begin using these new documents.

Click here to read HUB International's Client Bulletin.