Plan sponsors obligated to complete and distribute the SBC themselves (self-funded and account based plans) should familiarize themselves with these changes. The latest versions of the SBC are released in final form. Any changes relate to the elimination of the individual mandate payment. Unfortunately, the new materials have not cleared up confusion for account-based plans or whether “good faith” compliance standards will be accepted as they were in the past.
For complete details on the new SBC and its related materials, see the DOL webpage below:
Sample Summary of Benefits and Coverage for HRAs, click on the link below:
Sample Summary of Benefits and Coverage for ICHRAs, click on the link below: