On April 23rd, the DOL, HHS and IRS (the “Agencies”) released an updated template for the Summary of Benefits and Coverage (“SBC”) that group health plans and issuers are required to send to plan participants.  This updated SBC is the template to be used by plan sponsors and issuers to comply with the SBC requirements for the “second year of applicability”; i.e., for coverage beginning on or after January 1, 2014 and before January 1, 2015.  The good news is that the new SBC is largely the same as the template issued by the government for the “first year of applicability.”  The key differences are that the new document includes statements regarding whether a plan provides “minimum essential coverage” and whether the coverage meets the “minimum value” standard under the Affordable Care Act. The existing guidance on the means of distribution of SBCs (through electronic and other means) has not changed from last year.  The new template, sample completed SBC and related FAQs are available at the following links:

http://www.dol.gov/ebsa/pdf/correctedsbctemplate2.pdf

http://www.dol.gov/ebsa/pdf/CorrectedSampleCompletedSBC2.pdf

http://www.dol.gov/ebsa/faqs/faq-aca14.html

Photo of Gabrielle Fox Gabrielle Fox

Gabrielle Fox is a special employee benefits counsel in the Labor & Employment Law Department and a member of the Employee Benefits & Executive Compensation Group. She is involved in many aspects of employee benefits law, including the establishment and compliance of retirement…

Gabrielle Fox is a special employee benefits counsel in the Labor & Employment Law Department and a member of the Employee Benefits & Executive Compensation Group. She is involved in many aspects of employee benefits law, including the establishment and compliance of retirement plans (both defined benefit and defined contribution) as well as welfare plans.

Gabrielle counsels clients with regard to the requirements of ERISA, as well as the multitude of other laws affecting the employee benefits sphere. She provides day-to-day advice to boards of trustees and plan administrators regarding all issues related to the plan’s continued compliance with applicable law. In addition, she represents multiple clients within the theatre industry.

While in law school, Gabrielle clerked at the Nassau County Family Court for Special Referee Dorothy A. Phillips and assisted with the drafting of custody decisions. She was a member of the Hofstra Law Review and served as senior associate editor in her third year.

Photo of Roberta Chevlowe Roberta Chevlowe

Roberta K. Chevlowe provides advice to employers and boards of trustees of multiemployer benefit plans on a broad range of issues relating to their retirement, health and other employee benefit plans. With three decades of experience practicing in this area, Roberta employs a…

Roberta K. Chevlowe provides advice to employers and boards of trustees of multiemployer benefit plans on a broad range of issues relating to their retirement, health and other employee benefit plans. With three decades of experience practicing in this area, Roberta employs a practical, business-minded approach to helping her clients comply with the various requirements imposed by ERISA, the Internal Revenue Code, COBRA, the Affordable Care Act and other federal and state laws affecting employee benefit programs. Roberta’s practice also includes advising clients in connection with benefit claim appeals, lawsuits and government audits; drafting plan documents, policies and employee communications materials; and negotiating with plan service providers.

Roberta is best known for her work in the area of COBRA compliance and for advising employers in connection with the benefits they provide to employees’ domestic partners and same-sex spouses. She is a co-author of The COBRA Handbook and lectures and publishes articles on a variety of employee benefits topics. In addition, Ms. Chevlowe is a leader of Proskauer’s Task Force on Reproductive Health Care Benefits.