Concerned about the uniform benefit summaries due March 23, 2012?  Under PPACA, plans and insurers are required to furnish participants with a very abbreviated summary of benefits and coverage. This summer, proposed regulations on this requirement, were issued and some sample templates were released.  The DOL recently released some FAQs that provide that plans and insurers will not be required to distribute the summaries until final regulations are issued. The departments expect the final regulations to give plans and insurers sufficient time to comply with the final rules after they are published.  So, for now at least, it looks like the requirements to distribute these summaries is on hold.  Stay tuned.

In other news, the EBSA has created a new consumer assistance webpage (also available in Spanish) that allows users to submit questions and complaints about plans electronically.  The webpage also provides access to basic information relating to health and retirement benefit plans through several links under the following categories: Resources/Tools, Hot Topics, and Publications.  The topics covered include health plan issues such as COBRA eligibility, HIPAA special enrollment rights, and health care reform requirements and retirement plan matters such as filing a claim for benefits and understanding fees and expenses in 401(k) plans, all very hot topics.  Plan sponsors would do well to check it out for assistance in administering their plans.

Finally, HHS has issued information about its new Privacy and Security Audit Program.  This program will apply only to HIPAA-covered entities.  All audits conducted during this initial pilot period will include a site visit and result in a formal report.  Covered entities selected for audit will receive a notification letter approximately 30 to 90 days prior to the site visit.  If you receive one of these audit letters, make sure to respond and let your plan professionals know you have been selected.

Employee Benefits Legal Blog


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