Kilpatrick Townsend

DOL Issues Additional SBC Guidance

To date, I think the SBC requirement has the most DOL frequently asked questions. In fact, some of the SBC FAQs are even drafted similar to the PPACA statute itself, because later FAQs amend and revise earlier FAQs, making them even harder to read. However, today the most recent SBC guidance is simple. In a single FAQ, DOL makes it clear that retiree health plans, and Medicare advantage plans sponsored by employers, do not have an SBC requirement. A link to the FAQ can be accessed here:

http://www.dol.gov/ebsa/faqs/faq-aca10.html