DOL Issues Guidance on Second-Year SBCs

On April 23, 2013, the U.S. Department of Labor (“DOL”) issued a set of frequently asked questions (“FAQs”) addressing the summary of benefits and coverage (SBC) disclosure requirement under the Affordable Care Act.  The FAQs, which were jointly prepared by the Departments of Labor, Health and Human Services and Treasury, reflect changes to SBCs for the second year of applicability, which is coverage that begins on or after January 1, 2014, and before January 1, 2015. In conjunction with the FAQs, the Department of Labor provided an updated SBC template and sample completed SBC, both for the second year of applicability.  The FAQs can be found on the DOL website at

For more information about SBCs, please contact your Trust Fund counsel.

By Patricia Davis

Legal Developments