Final SBC Rules Issued

As background, the Affordable Care Act (“ACA”) requires a summary of benefits and coverage (“SBC”) and uniform glossary to be provided to plan participants at time of enrollment. Significant penalties (up to $1,000) may be imposed for each...

2015 Midyear Compliance Compilation

On December 19, 2014, the Departments of Labor, the Internal Revenue Service and Health and Human Services issued a proposed rule that provides helpful guidance with respect to certain wraparound programs.