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SUMMARY OF BENEFITS 
& COVERAGE 
The ACA requires you to 
provide an SBC to all 
applicants and enrollees 
for all group health 
plans, except for those 
that are excepted 
benefits under HIPAA. 
This requirement is 
eective for open 
enrollment periods that 
started on or after 
September 23, 2012. 
GRANDFATHERED PLAN 
NOTICES 
Employers must send 
this notice to all 
participants if the plan is 
to maintain its 
grandfathered status. 
Grandfathered plans do 
not have to comply with 
some of the rules 
related to the ACA. 
However, they must 
comply with other rules, 
like annual and lifetime 
limits, dependent 
coverage up to age 26, 
rescission and limits on 
preexisting condition 
exclusions (PCEs). 
PATIENT PROTECTION 
DISCLOSURES 
Also under the ACA, 
employers must notify 
participants of their right 
to designate any primary 
care provider who 
participates in the 
network. If the plan 
allows for the 
designation of a 
primary care provider 
for a child or for an 
obstetric/gynecological 
care provider, these 
must also be included 
in the notice. 
MEDICARE PART D CREDITABLE 
COVERAGE NOTICES 
All employer-sponsored 
plans that oer a 
prescription drug benefit 
must annualy notify 
participants as to whether 
their coverage is creditable 
or non-creditable. The 
deadline to mail these 
notices is October 15. The 
Medicare Part D annual 
enrollment period is 
October 15 through 
December 7. This will 
require notices to go out 
prior to most plans being 
finalized. Any changes to 
creditable status once a 
plan is finalized will 
require another round of 
notices to be sent. 
COBRA QUALIFIED 
BENEFICIARY 
COMMUNICATIONS 
COBRA regulations, as 
amended by HIPAA 
require many notices; 
one of those is the Open 
Enrollment Notification. 
This requirement states 
that employers must 
provide the same rights 
to COBRA Continuees 
during an open 
enrollment period that 
is oered to active 
employees. This notice 
is required even if the 
only change is the 
COBRA rates. The 
open enrollment 
packet must be sent to: 
HEALTH FSAs 
Health FSAs are another 
open enrollment 
challenge. If the Health 
FSA is a HIPAA-excepted 
benefit and the employer 
need only oer COBRA 
when the FSA account is 
underspent, then the 
COBRA obligation ends 
at the end of the first 
plan year. However, if the 
employer somehow does 
not qualify for the limited 
obligation, the employer 
must provide the 
opportunity to elect 
Health FSA coverage for 
the next plan year or until 
COBRA has been 
exhausted. Also, if the 
COBRA period is also 
covered by USERRA 
because of a military 
leave of absence, the 
employer must continue 
to oer the Health FSA. 
copyright 2014

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Hospital HEALTHCARE WASTE Management MANUAL.pdf
 

6 Open Enrollment Items

  • 1. SUMMARY OF BENEFITS & COVERAGE The ACA requires you to provide an SBC to all applicants and enrollees for all group health plans, except for those that are excepted benefits under HIPAA. This requirement is eective for open enrollment periods that started on or after September 23, 2012. GRANDFATHERED PLAN NOTICES Employers must send this notice to all participants if the plan is to maintain its grandfathered status. Grandfathered plans do not have to comply with some of the rules related to the ACA. However, they must comply with other rules, like annual and lifetime limits, dependent coverage up to age 26, rescission and limits on preexisting condition exclusions (PCEs). PATIENT PROTECTION DISCLOSURES Also under the ACA, employers must notify participants of their right to designate any primary care provider who participates in the network. If the plan allows for the designation of a primary care provider for a child or for an obstetric/gynecological care provider, these must also be included in the notice. MEDICARE PART D CREDITABLE COVERAGE NOTICES All employer-sponsored plans that oer a prescription drug benefit must annualy notify participants as to whether their coverage is creditable or non-creditable. The deadline to mail these notices is October 15. The Medicare Part D annual enrollment period is October 15 through December 7. This will require notices to go out prior to most plans being finalized. Any changes to creditable status once a plan is finalized will require another round of notices to be sent. COBRA QUALIFIED BENEFICIARY COMMUNICATIONS COBRA regulations, as amended by HIPAA require many notices; one of those is the Open Enrollment Notification. This requirement states that employers must provide the same rights to COBRA Continuees during an open enrollment period that is oered to active employees. This notice is required even if the only change is the COBRA rates. The open enrollment packet must be sent to: HEALTH FSAs Health FSAs are another open enrollment challenge. If the Health FSA is a HIPAA-excepted benefit and the employer need only oer COBRA when the FSA account is underspent, then the COBRA obligation ends at the end of the first plan year. However, if the employer somehow does not qualify for the limited obligation, the employer must provide the opportunity to elect Health FSA coverage for the next plan year or until COBRA has been exhausted. Also, if the COBRA period is also covered by USERRA because of a military leave of absence, the employer must continue to oer the Health FSA. copyright 2014