The Departments of Labor, Health and Human Services and the IRS just announced that, until final regulations are issued and made applicable, plans and insurers are not required to comply with the requirement under health care reform to furnish the Summary of Benefits and Coverage or the Uniform Glossary that were originally required to be distributed by March 23, 2012.

As you may recall, in August 2011, proposed regulations were issued, which included guidance on when, how and to whom the SBC must be distributed, templates, instructions and related materials to assist with the SBC and Uniform Glossary (details regarding these provisions were provided to you in September 2011).  The guidance left many questions unanswered and further guidance was expected.

The agencies anticipate that the final regulations will include an applicability date that gives group health plans and insurance carriers sufficient time to comply with the requirement. Therefore, until final regulations are issued and an applicability date (a date by which to comply) is provided, carriers and plan sponsors are not required to provide SBCs.

Once final guidance has been issued, we will keep you updated.