COMPLIANCE DATES
APRIL 30, 2017 for new health plans on a calendar plan year: Summary Plan Description (“SPD”)
Employers who offer a health insurance plan must provide SPDs to all participants within 120 days after a new plan is adopted. SPDs must also be provided to new participants no later than 90 days after the person first becomes covered under the plan.
FEDERAL COMPLIANCE UPDATES
NEW VERSIONS OF SBC DOCUMENTS
New versions of the Summary of Benefits and Coverage (“SBC”) template, instructions, uniform glossary, and related documents are required to be used on or after April 1, 2017. Under the Affordable Care Act, group health plans and health insurance issuers are generally required to provide a written SBC to plan participants and beneficiaries at specified times during the enrollment process and upon request.
Click here to access the new SBC template and related materials from the U.S. Department of Labor.
FLSA/ OVERTIME RULING POSTPONED UNTIL MAY 1
A federal appeals court has granted the U.S. Department of Labor until May 1, 2017 to take an official position on the pending overtime regulations. The rules, which were scheduled to take effect December 1, 2016, would have required employers to pay overtime to employees earning less than $913 per week (which amounts to $47,476 annually).
Information will be released in future Legal Updates as additional details become available.
PERIOD EXTENDED FOR HRA
The IRS recently released Notice 2017-20, which extends the notice requirement period for an employer that provides a qualified small employer health reimbursement arrangement (“QSEHRA”).
Under the 21st Century Cures Act, employers that offer a QSEHRA are required to provide an initial written notice to its eligible employees. The notice period has been extended from March 13, 2017 (90 days after the Cures Act was enacted) to at least 90 days after additional forthcoming guidance regarding the contents of the QSEHRA notice is issued.
For additional details, see Extension Notice.
For assistance or information about our SPD Wrap service, contact HR Service at: (855) 447-3375.