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Four-Page Benefit Summary Requirement for Group Health Plans Arrives in 2012
by Greg Gautam and Nancy Campbell
Section 2715 of the Public Health Service Act, which was added by the Patient Protection and Affordable Care Act as amended by the Health Care and Education Reconciliation Act of 2010 (collectively, the “Act”) expands ERISA’s disclosure requirements by requiring group health plans to provide a four-page summary of benefits and coverage (the “SBC”) to applicants and enrollees before enrollment or re-enrollment. All group health plans, including grandfathered plans, will be required to furnish SBCs effective March 23, 2012. Retiree-only and HIPAA-excepted plans, such as stand-alone dental and vision plans, are not subject to this new requirement.