Greetings!
Health Care Reform (aka PPACA) final guidance on the Summary of Benefits & Coverage is out, which means deadlines to meet. Additionally, the final rule on GINA Recordkeeping has been issued. We provide highlights from each here, along with handy links to the appropriate sites.
If you need help or have questions on how any of these changes may affect your employee benefit plan, please remember, your EmSpring representative is here to help!
Best regards,
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| Ready Your Summary of Benefits & Coverage |
The delay is over. Mark September 23, 2012 on your calendar. Beginning then, plans must provide the Summary of Benefits & Coverage to participants and beneficiaries enrolling or re-enrolling for coverage during the open enrollment period.
Additionally, newly eligible or special enrollees who enroll outside of the open enrollment period also must receive the Summary. Applicable date: first day of the first plan year beginning on or after 9/23/2012.
If your organization follows a calendar year plan and its annual open enrollment generally takes place before the start of the plan year, then you'll begin providing the SBC for the 2013 plan year - on the first day of the open enrollment period held in 2012.
The aim is that the Summary of Benefits & Coverage will show in clear, straightforward language what the coverage is so that consumers can easily compare various benefits and coverage.
HHS provides a template and uniform glossary, along with related program information.
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EEOC & GINA Recordkeeping
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Hang onto those records!
Effective April 3, 2012: The final rule extends the EEOC's existing recordkeeping requirements that currently apply under Title VII of the Civil Rights Act of 1964 and the ADA to those employers covered by Title II of GINA.
So for one year from the date the record was made or the personnel action was taken (whichever is later), employers must keep those records. This includes those for involuntary terminations. Documents and records may include:
- Requests for reasonable accommodation
- Application forms
- Hiring, firing, promotion, demotion, transfer, lay-off
- Pay rates & compensation, tenure, training or apprenticeship
Plus, if there's a discrimination charge filed under Title VII, the ADA or GINA (or civil action via EEOC or the AG), employers have to keep the related records until everything is over - final disposition.
For details, see the EmSpring Legislative Brief or the EEOC final rule document online.
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EmSpring is an employee benefits firm with an emphasis on health insurance and self-funded medical plans, benefits and plan design, HR and integrated payroll technology. Our clients are Pacific Northwest companies who consider their employees to be their greatest asset. We provide insurance options and advice for you, your family and your business.
Members of a national alliance of independent firms, we are your local experts and resource for benefits advice, HR solutions and payroll technology. We are employee-owned and client-driven. Give us a call at 877.550.0088 to learn how we can help you and your organization.
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