By now, many questions regarding health care reform have been answered, but there are still a good number of clarifications that need to be made in the coming months. One of those clarifications is regarding the four-page summary of benefits and coverage required under health care reform.

Health care reform expanded ERISA's disclosure requirements by requiring that a four-page "summary of benefits and coverage" be given to enrollees before enrollment occurs. The four page summary does not replace the SPD - it must be provided by plan administrators and insurers in addition to the SPD (and SMMs) required under ERISA. The four-page summary requirement applies to grandfathered plans, but not to certain "excepted benefits." Although effective for plan years beginning on or after September 23, 2010, the four-page summary requirement contains a special distribution deadline of 24 months after the enactment of health reform (March 23, 2010). HHS must issue guidance addressing the four-page summary by March 23, 2011 (i.e. 12 months after the enactment date).

Health care reform sets out specific appearance and language requirements for what the summary should look like - including that it be presented in a uniform format and that it not be longer than four pages.

The summary must satisfy a lengthy list of content requirements - all within the permitted four-page limit. The required information includes uniform definitions of standard insurance and medical terms, along with a description of the group health plan's coverage for each of the "essential health benefits." The summary must also describe exceptions, reductions, and limitations on coverage; as well as cost-sharing provisions, including deductible, co-insurance, and co-payment obligations. It must also provide the telephone number to call for additional questions, and the web address where a copy of the group certificate of coverage or SPD can be reviewed and obtained.

As your advisor, we will work with you to meet this new requirement. As we get more details and information, we wil be passing it onto you. Please let us know if you have any questions - thank you and have a great week! 

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