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Another new communication requirement is the summary of benefits and coverage (SBC), which is a uniform, easy-to-understand format that can facilitate comparison shopping. This does not replace an SPD, Sinkeldam said. Most employers will want their vendors to draft the SBCs, Sinkeldam said, adding that employers should discuss who will be responsible for distributing these materials after they are created. Under the Employee Retirement Income Security Act (ERISA), which covers many notices, employers must deliver them in a way that is “reasonably calculated to ensure actual receipt of the material” using a method “likely to result in full distribution.” This means employers cannot just post notices on an office bulletin board or leave them in a pile in the break room, said Wade Symons, employee benefits attorney at Mercer. “They really want individual receipt as the key,” he said.
Another new communication requirement is the summary of benefits and coverage (SBC), which is a uniform, easy-to-understand format that can facilitate comparison shopping. This does not replace an SPD, Sinkeldam said.
Most employers will want their vendors to draft the SBCs, Sinkeldam said, adding that employers should discuss who will be responsible for distributing these materials after they are created.
Under the Employee Retirement Income Security Act (ERISA), which covers many notices, employers must deliver them in a way that is “reasonably calculated to ensure actual receipt of the material” using a method “likely to result in full distribution.” This means employers cannot just post notices on an office bulletin board or leave them in a pile in the break room, said Wade Symons, employee benefits attorney at Mercer.
“They really want individual receipt as the key,” he said.
Corie Russelleditors@plansponsor.com