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December 8, 2011
Summary of Coverage Compliance Date Delayed
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On November 17th the Department of Labor (DOL) released a series of "Frequently Asked Questions" (FAQ) in
relation to the Summary of Coverage. The FAQs clarified some of the items that were addressed in the
proposed regulations for the Summary . which were released earlier this year.
Of extreme importance, in the FAQs the DOL delays the date for providing the Summary. The DOL indicates that plans can wait to start providing the Summary until after the final regulations addressing the Summary have been released. This means the March 23, 2012 deadline will no longer apply.
It is uncertain when the Summary regulations will be released. The DOL has indicated that plans will be given sufficient time after the release of the final regulations to prepare for complying with the requirements for the Summary as described in the final regulations.
The Patient Protection and Affordable Care Act (PPACA) requires a Summary to be distributed for each plan option. Additionally, a revised Summary must be distributed no less than 60 days before any subsequent benefit changes can be made. The Summary must be distributed for all plans (grandfathered and nongrandfathered). On August 22, 2011 the Department of Health and Human Services, Department of Labor and Department of Treasury jointly issued proposed regulations for the Summary. The proposed regulations included guidance on providing and preparing the Summary and a proposed template for the Summary.
More information about the Summary of coverage as well as the FAQs is available at http://www.dol.gov/ebsa/faqs/faq-aca7.html
Please feel free to contact your NGS CoreSource Client Services Team should you have any further questions or
concerns.
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Summary of Coverage Compliance Date Delayed 
