No Delay for Implementation of Summary of Benefits and Coverage

March 20, 2012 ( – Officials issued frequently asked questions (FAQs) regarding implementation of the summary of benefits and coverage (SBC) provisions of the Affordable Care Act.

The Departments of Labor, Health and Human Services (HHS), and the Treasury in February published the final rules regarding the SBC (see “EBSA Releases Final PPACA Regulations”). The FAQs aim to answer some of the questions that have been raised to date. The agencies said they intend to release additional FAQs.  

The American Benefits Council expressed disappointment that the new guidance did not indicate an extension in the time to comply with SBC rules. We had urged the agencies to either delay the effective date by twelve months or provide a transition rule to allow employers to meet these new obligations as smoothly as possible,” Council President James A. Klein said in statement.  

“Disclosure and communications regarding health benefits are an important component of benefit plan administration and design, and we appreciate the daunting task the agencies face in implementing the new law. But while the federal government gave itself the extra time needed to craft the rules, employers and their administrative partners must now work double-time to perform the more difficult job of implementing these standards in the next six months,” Klein contended.  

“The guidance issued today restates that these new disclosures must be provided by most employers starting September 23, 2012, but the Council will continue to pursue every opportunity to obtain needed flexibility and adequate time for employers to comply,” he added.  

The FAQs are available at