Sunday, February 13, 2011

US Department of Labor announces intention to extend applicability date of section 408(b)(2) fee disclosure regulation

The U.S. Department of Labor's Employee Benefits Security Administration announced that it intends to extend the applicability date for the new disclosure rules under section 408(b)(2) of ERISA to Jan. 1, 2012.
http://www.dol.gov/ebsa/newsroom/2011/ebsa021111.html

Thursday, February 10, 2011

Creditable Coverage Disclosure to CMS

If your plan provides prescription drug coverage, you must provide your Part D eligible employees a notice regarding creditable or non-creditable status of the coverage before the Medicare Part D annual enrollment period.   In addition, you must disclose to CMS whether the prescription drug coverage that is offered to a Medicare Part D eligible individual is creditable or non-creditable no later than 60 days after the beginning of each plan year or March 1, 2011 for calendar years.

Friday, February 4, 2011

February 7, 2011 notice deadline for plans that obtained waiver of annual limit rules

As a condition of receiving a waiver from the annual limit requirements under Health Care Reform, a group health plan must provide a notice to eligible participants.  OCIIO guidance 2010-1B issued last December provides a sample notice with the requirement that it be displayed “in clear, conspicuous 14 point bold type on the front of materials”.  For plans that have already been approved for a waiver for plan years beginning before February 1, 2011 or that will receive approvals for plan years that begin before February 1, 2011, the notice must be provided by February 7, 2011.  For plan years beginning on or after February 1, 2011, the notice must be provided to eligible participants as part of any informational or educational materials and also in any plan documents evidence coverage that is sent to enrollees such as enrollment material or summary plan descriptions.