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The Wagner Law Group Description 

The Wagner Law Group, A Professional Corporation, is a nationally recognized ERISA & employee benefits, estate planning, employment, labor & human resources practice. 


Established in 1996, The Wagner Law Group has 22 attorneys engaged exclusively in employee benefits, estate planning and employment law. Six of our attorneys are AV rated by Martindale-Hubbell as having very high to preeminent legal abilities and ethical standards. The firm is among the largest ERISA boutiques in the country. Our practice is national in scope, with clients in more than 40 states and several foreign countries.






Contact Info

The Wagner Law Group


  Integrity | Excellence


Massachusetts Office 

Tel: (617) 357-5200 

Fax: (617) 357-5250 

99 Summer Street 

13th Floor

Boston, MA 02110

Florida Office 

Tel: (561) 293-3590
Fax: (561) 293-3591
7108 Fairway Drive
Suite 125
Palm Beach Gardens, FL 33418


San Francisco Office

Tel: (415) 625-0002

Fax: (415) 358-8300

315 Montgomery Street

Suite 904

San Francisco, CA 94104







December 31, 2014


 Health and Welfare Law Alert




Agencies Propose Changes to SBC






IRS, DOL and HHS have issued proposed regulations modifying the requirements for the Summary of Benefits and Coverage ("SBC").


The Patient Protection and Affordable Care Act ("ACA") requires group health plans or their health insurers to distribute a uniform explanation of benefits and coverage to plan participants and beneficiaries, and other individuals eligible to enroll in the plan. In particular, SBCs are intended to provide a better understanding of the health care coverage offered, and a basis of comparison with other health plans.


Insurers who provide coverage to group health plans are required to provide SBCs to these individuals as well as to the plan itself. However, individuals need only receive one SBC from either the insurer or the group health plan administrator. 


Among the proposed changes: 

  • The anti-duplication rules have been expanded to clarify that a plan administrator may contract to require another entity to provide the SBC.
  • The SBC must state whether the plan offers minimum essential coverage and meets the minimum value requirement.
  • The SBC must provide a third example of coverage (emergency treatment of a broken foot).
  • The proposal clarifies what an SBC must provide when the terms of coverage are not yet finalized.
  • The sample SBC has been modified and reduced to five pages, allowing plan administrators and insurers room for additional information relating to a particular plan. 

The new rules are expected to be effective September 1, 2015. The revised sample SBC is available at: http://www.dol.gov/ebsa/pdf/sbctemplateproposed.pdf.




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This Newsletter is provided for information purposes by The Wagner Law Group to clients and others who may be interested in the subject matter, and may not be relied upon as specific legal advice.  This material is not to be construed as legal advice or legal opinions on specific facts. Under the Rules of the Supreme Judicial Court of Massachusetts, this material may be considered advertising.