The FAQs make clear that compliance will not be required until final rules are issued and effective.
Background Proposed rules issued in August established the standards for group health plans to provide participants and beneficiaries a summary of benefits and coverage (SBC), as well as a uniform glossary of terms commonly used in health insurance coverage, as required under the Affordable Care Act. Both documents must comply with certain appearance and format requirements and must utilize terminology understandable by the average plan enrollee.
Under the proposed rules, the new requirement would be applicable beginning March 23, 2012.
Compliance Not Required Before Final Rules Become Effective According to the FAQs, final regulations regarding the SBC and uniform glossary are expected to be issued as soon as possible, taking into account comments and feedback on the proposed rules and the proposed templates to satisfy these requirements that were issued simultaneously. Until those final regulations are issued, group health plans are not required to comply with the requirement to provide the SBC and uniform glossary. It is anticipated that the final regulations, once issued, will include an applicability date that gives group health plans sufficient time to comply.