The Wagner Law Group Description
Wagner Law Group, A Professional Corporation, is a nationally
recognized ERISA & employee benefits, estate planning,
employment, labor & human resources practice.
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.
Wagner Law Group
Fax: (561) 293-3591
7108 Fairway Drive
Palm Beach Gardens, FL 33418
Francisco, CA 94104
December 31, 2014
Health and Welfare Law
Agencies Propose Changes to
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
Among the proposed
anti-duplication rules have been expanded to clarify that a plan
administrator may contract to require another entity to provide
- 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
- 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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