Final regulations were released earlier this year that amended the effective date of this requirement from March 23, 2012 to September 23, 2012. A full article (with the exception of this date change) is posted in our Benefits Guide, but here’s a summary of the key points:

• Your carrier or third party administrator (TPA) should provide this document to you as an employer. However, it is then your responsibility to see that is provided to employees as applicable.
• Remember that this takes effect with your next renewal after September 23rd, but new hires between now and then, any qualifying events, etc. mean you must provide the SBC starting as soon as next month in a number of off-anniversary situations.
• Because minimum essential coverage requirements are still being finalized, the inclusion of premium information does not have to be provided with the SBC at this time. We expect that by January 1st, 2014, however, premium information will also need to be included.
• Don’t forget that you must provide the SBC to both plan participants and their beneficiaries and that there is a seven day timeline from the date of request or qualifying event.

Got questions? Contact us directly for further clarification on this or any other PPACA provisions that we can assist your organization with.