Summaries of Benefits & Coverage (SBC) Who What All applicants and enrollees for all group health plans, except HIPAA-excepted benefits (e.g., stand-alone dental, vision, most Health FSAs). When This annual requirement is currently in effect. The ACA requires employers to provide an SBC, a four-page, double-sided summary that allows health care consumers to compare coverage options. Grandfathered Plan Notices Who What ACA requires that this notice be provided to all participants if the plan is to maintain its grandfathered status. When This annual requirement is currently in effect and continues as long as the group health plan maintains its grandfathered status. A notice explaining that the plan or coverage is a grandfathered health plan with the ACA definition. Why Grandfathered plans do not have to comply with some of the rules related to the ACA. Health FSAs Who If the Health FSA is a HIPAA-excepted benefit and the employer need only offer COBRA when the FSA account is under spent, then the COBRA obligation ends at the end of the first plan year. However, if the employer somehow does not qualify for the limited obligation, the employer must provide the opportunity to elect Health FSA coverage for the next plan year. What Included with open enrollment notification of available coverage. When During open enrollment period. Model Exchange Notice Who What Applies to all employers that are subject to the Fair Labor Standards Act, as amended by the Affordable Care Act (ACA). When The Model Notice must be sent no later than October 1, 2013. After that date, it must be provided within 14 days to all new hires. The Model Exchange Notice must be sent to all current employees, even those who may not meet the ACA definition of full-time employee. COBRA Qualified Beneficiary Communications Who What The open enrollment packet must be sent to individuals in their 60-day election period, individuals who have elected but have not yet paid and individuals who have elected and paid. When The open enrollment notification is required even if the only change is the COBRA rates. This requirement states that employers provide the same rights to COBRA participants during an open enrollment period that are offered to active employees. Medicare Part D Creditable Coverage Notices Who What All employer-sponsored plans that offer a prescription drug benefit must notify participants as to whether their coverage is creditable or non-creditable. The annual deadline to mail these notices is October 15. This means notices may go out prior to most plans being finalized. When Medicare Part D is the prescription drug program that has been in effect since 2006. Patient Protection Disclosures Who What Employers must notify participants of their right to designate any primary care provider who participates in the network. When This notice provides individuals enrolled in the health plan information regarding rights to choose a primary care provider or a pediatrician when a plan or issuer requires designation of a primary care physician or obtain obstetrical or gynecological care without prior authorization. The annual notice must be provided whenever the plan provides an SBC. This requirement is currently in effect. Are you Prepared With Annual Notice Requirements? We’ve put together a list of required annual notices to help you stay on top of compliance.
Are you Prepared With Annual Notice Requirements?
Jul 29, 2015
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Summaries of Benefits & Coverage (SBC)
Who
What
All applicants and enrollees for all group health plans, except HIPAA-excepted benefits (e.g., stand-alone dental, vision, most Health FSAs).
When This annual requirement is currently in effect.
The ACA requires employers to provide an SBC, a four-page, double-sided summary
that allows health care consumers to compare coverage options.
Grandfathered Plan Notices
Who
What
ACA requires that this notice be provided to all participants if the plan is to maintain its grandfathered status.
When This annual requirement is currently in effect and continues as long as the group health plan maintains its grandfathered status.
A notice explaining that the plan or coverage is a grandfathered health plan
with the ACA definition.
WhyGrandfathered plans do not have to comply with some of the rules related
to the ACA.
Health FSAs
Who
If the Health FSA is a HIPAA-excepted benefit and the employer need only offer COBRA when the FSA account is under spent, then the COBRA obligation ends at the end of the first plan year. However, if the employer somehow does not qualify for the limited obligation, the employer must provide the opportunity to elect Health FSA coverage for the next plan year.
What Included with open enrollment notification of available coverage.
WhenDuring open enrollment period.
Model Exchange Notice
Who
What
Applies to all employers that are subject to the Fair Labor Standards Act, as amended by the Affordable Care Act (ACA).
When The Model Notice must be sent no later than October 1, 2013. After that date, it must be provided within 14 days to all new hires.
The Model Exchange Notice must be sent to all current employees, even those who
may not meet the ACA definition of full-time employee.
COBRA Qualified Beneficiary Communications
Who
What
The open enrollment packet must be sent to individuals in their 60-day election period, individuals who have elected but have not yet paid and individuals who have elected and paid.
When The open enrollment notification is required even if the only change is the COBRA rates.
This requirement states that employers provide the same rights to COBRA participants during an open enrollment period that are offered to active employees.
Medicare Part D Creditable
Coverage Notices
Who
What
All employer-sponsored plans that offer a prescription drug benefit must notify participants as to whether their coverage is creditable or non-creditable.
The annual deadline to mail these notices is October 15. This means notices may go out prior to most plans being finalized.
When
Medicare Part D is the prescription drug program that has been in effect
since 2006.
Patient Protection Disclosures
Who
What
Employers must notify participants of their right to designate any primary care provider who participates in the network.
WhenThis notice provides individuals enrolled in the health plan information regarding rights to choose a primary care provider or a pediatrician when a plan or issuer requires designation of a primary care physician or obtain obstetrical or gynecological care without prior authorization.
The annual notice must be provided whenever the plan provides an SBC. This
requirement is currently in effect.
Are you Prepared With Annual Notice Requirements?
We’ve put together a list of required annual notices to help you stay on top of compliance.
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