Additional Guidance on the Summary of Benefits and Coverage
May 11, 2012 | DOL
The agencies posted 14 additional FAQs related to the Summary of Benefits and Coverage (SBC) along with "corrected" versions of the blank and completed versions of the SBC.

CCIIO Bulletin on Verifying Employer Coverage
April 30, 2012
CCIIO released a bulletin regarding how HHS is approaching how an Exchange will obtain information from applicants regarding employer coverage. Individuals are NOT eligible for premium tax credits if they are eligible (as employees or dependents) for adequate and affordable employer health plan coverage or if they are actually enrolled in employer coverage (regardless whether it is adequate and affordable). The bulletin suggests that HHS is considering a two-part interim strategy: 1. A standardized approach for employees and employers to voluntarily collect and communicate information on employer coverage, and 2. Exchange verification of employer coverage, both pre-enrollment (based on existing data sources) and post-enrollment (based on a manual verification process). The bulletin seeks public comment on potential data sources for employer coverage, the options for Exchanges to obtain employer coverage information directly from employers, and how Exchanges can achieve real-time verification of employer coverage information during the enrollment process. No date is specified for the submission of comments.

Comparative Effectiveness Research (CER) Fee - Proposed Regulations
April 12, 2012
The IRS released proposed regulations describing how the ACA's comparative effectiveness research (CER) fee must be calculated and paid by health insurance carriers and sponsors of self-insured plans. With respect to self-insured plans, the regulations describe which plans are subject to the fees (generally all plans, including retiree-only plans; however, exemptions apply for (i) plans covering HIPAA-exempt benefits (such as stand-alone dental and vision plans and most health FSAs), and (ii) EAPs, disease management and wellness programs that don't provide significant medical benefits), which plan sponsors must pay (generally all plan sponsors), the amount of the fees ($1 times average covered lives the first year, $2 times average covered lives the second year, and inflation-adjusted amounts times average covered lives in following years), various approaches for determining the number of average-covered lives (the "actual count" method, the "snapshot" method and the "Form 5500" method), and when the fees must be reported and paid (by each July 31 following the end of a plan year; the fees are reported and paid with Form 720 which may be filed electronically).

SBC Guidance via FAQ
March 19, 2012 | DOL
The Departments of HHS, Labor and the IRS issued FAQ Part VIII with implementation guidance regarding implementation of the summary of benefits and coverage (SBC) provisions of the Affordable Care Act. Included is information regarding the circumstances in which an SBC may be provided electronically.