In the face of the circling swarm of uncertainties surrounding the implementation of Healthcare Reform in these here United States, I’ve learned to take comfort in one thing: it’s not just me. It seems nobody really knows what’s going on or how to do any of this. And that means the date I need to comply with what nobody seems to understand has been delayed until they decide when I need to comply. All together now . . . .
On November 17th, 2011, the Department of Health and Human Services (HHS), Department of Labor (DOL), and the Treasury issued an answer to a Frequently Asked Question (FAQ) that stated group health plans don’t need to comply with the Summary of Benefits and Coverage and Uniform Glossary requirement of the Patient Protection and Affordable Care Act (PPACA) until they come up with some final regulations on the subject. (I’m guessing the original FAQ that prompted this response was, “Um . . . what?”)
Long story short, the Benefits Summary etc. requirement that you needed to begin complying with on March 23rd, 2012 no longer has an effective compliance date.