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Greetings!
60-Day
Advance Notice of Plan Changes:
Effective Date Issues
Overview of Effective Date
"Controversy"
Under a provision in the new federal health reform law, a plan
sponsor must provide persons
covered by the plan with notice of modifications at least 60 days
prior to the date the change
becomes effective. There has been significant confusion regarding
the effective date of this
provision. While healthcare reform laws provide specific deadlines
for many other rules, this provision lacks an explicit effective
date, and the new statutes are riddled with inconsistencies
with
respect to the effective date. Some have interpreted the law
taking effect for plan years on or after October 1, 2010; while
others believe the effective date is later.
Despite the inconsistencies, most benefit lawyers are of the
opinion that the deadline for providing
the notice of material modifications to the benefit plans will be
delayed until March 23, 2012 unless
in the interim, the Department of Health & Human Services
("HHS") provides further clarification
and creates an earlier deadline.
Conclusion
Given the apparent delay in the application of the new plan
modification law to March 23, 2012, plan sponsors have some time to
await agency guidance from HHS. We will be monitoring this issue
closely, and once HHS clarifies its position, we will issue another
benefit alert.
We Can Help
We are dedicated to serving our clients by understanding and
carefully monitoring the legislation, regulatory developments and
the marketplace of responses to these provisions. We are committed
to assisting our clients in assessing alternatives and designing
and implementing cost effective and practical strategies to comply
with the legislation, including decisions to retain, modify or
surrender grandfathered plan status.
An essential partner to businesses and their owners, SRA Benefits
closely monitors legislation that affects our clients. With access
to legislative and regulatory specialists in Washington, D.C. and
utilizing expert, in-house sources of legal, actuarial and
compliance guidance, SRA Benefits will continue to provide the
latest information on health care reform.
SRA Benefits is ready to provide you with the coverage you need,
when you need it. To speak with a benefit consultant about the
right plans for your business, your employees, and yourself, call
913-236-3090 or email us at info@srabenefits.com.
Disclaimer: This benefit alert is for general informational
purposes only. While we have attempted to provide current, accurate
and clearly expressed information, this information is provided "as
is" and SRA Benefits makes no representations or warranties
regarding its accuracy or completeness. The rules and regulations
in connection with healthcare reform are fluid. The information
provided should not be construed as legal or tax advice or as a
recommendation of any kind. External users should seek professional
advice from their own attorneys and tax and benefit plan advisers
with respect to their individual circumstances and needs.
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Sincerely,
David Wetzler
SRA Benefits LLC |
SRA is a premier insurance advisory firm
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