Get ready for new required notices and definitions. Be prepared to update your communications for plan participants.  Last week, the departments of Labor and Health and Human Services (with the Treasury) laid out the new proposed rules for the "uniform summary of coverage" that is required under PPACA. Health insurers and group health plans have to provide consumers with clear, consistent and comparable information about their health plan benefits and coverage starting in 2012.

All health plans and issuers would provide a summary of benefits and coverage, along with a uniform glossary of terms to employees before enrollment.  Health plans and issuers will also provide notice at least 60 days before any significant modification is made in the plan or coverage during the plan or policy year. You could insert a lot of fancy discussion here about what the purpose of the provision is but, in short, it is a dumbing down of the summary of benefits coverage into some simple standard boxes for comparison shopping. If the exchanges ever actually come into existence, this would allow an employee to compare employer sponsored coverage against other market-available options.

For more details about the proposed regulations, check out the Model Summary of Coverage, the Fact Sheet requesting public comment and, of course, the proposed regulations. As these are merely proposed, there is nothing final and employers do not have to immediately act, nor can then act until the proposed uniform definitions are drafted. But employers and plan sponsors should keep this information handy as a reference point for developing a long-term compliance strategy. 


Keith R. McMurdy, partner at Fox Rothschild LLP in New York, can be reached at 212.878.7919 or

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