Health Care Reform requires all group health plans and health insurance issuers to furnish a uniform summary of benefits and coverage (“SBC”) to plan participants by March 23, 2012. The SBC is meant to describe the benefits and coverage of each available health coverage option in a concise and uniform format so that employees can easily compare, contrast and understand the options being offered to them.

Proposed SBC regulations have been recently issued by the federal agencies. These regulations include guidance on who is responsible for providing the SBC, who receives it, the deadline for furnishing it and how it must be provided, and includes SBC templates, instructions and related materials (visit http://www.dol.gov/ebsa/healthreform for more information). Note that a group health plan’s obligation to furnish an SBC to plan participants is in addition to ERISA’s requirements regarding the provision to plan participants of a summary plan description and summaries of material modification.

Employers should coordinate with their insurance carriers for fully insured plans and/or third-party administrators for self-funded plans to ensure that their group health plans are prepared to meet these SBC requirements in March 2012.