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Additional Guidance Issued on Summary of Benefits and Coverage Disclosure Requirements

by Amy M. Gordon and Joanna C. Kerpen

The U.S. Departments of Labor, Health and Human Services, and the Treasury recently issued new guidance and templates regarding the summary of benefits and coverage requirement under the Patient Protection and Affordable Care Act.

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Finalized ACA Regulations on Transitional Reinsurance Program Premiums and Potential Effects for Employer-Sponsored Group Health Plans

by Amy M. Gordon, Susan M. Nash and Jacob Mattinson

As part of the Patient Protection and Affordable Care Act, the U.S. Department of Health and Human Services (HHS) recently released final regulations regarding the transitional reinsurance program fee effective in CY 2014.  Effective May 10, 2013, the regulations address the estimated amount of annual contributions that will be paid to HHS from employer-sponsored group health plans, the types of welfare plans that are subject to the fee, the applicability of the fee to COBRA coverage and the treatment of certain retiree benefits.

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