| SBC (Summary of Benefits & Coverage) |
Group health plan sponsors or Issuers of insurance (not both) |
Federal template must be used. Describes plan to all participants. |
| WCHRA Notice |
Group health plans with medical & surgical coverage for mastectomies |
Must be provided at enrollment and annually thereafter. Can be covered in SPD instead. (DOL provides model language in Compliance Assistance Guide) |
| CHIP Notice |
Group plans covering residents in state providing premium assistance under MedicAid or CHIP |
Must be provided to all employees who are residents of state providing that kind of assistance. DOL has model notice employers may use. |
| SPD (Summary Plan Description) |
Group health plans subject to ERISA |
Must be provided to all new plan participants within 90 days of start of coverage. New SPD must be provided every 5 years if plan has changed, every 10 years if not. |
| SMM (Summary of Material Modifications) |
Plan sponsor |
Must be provided within 210 days after close of plan year in which change was made. However, if change is a reduction in benefits, deadline is 60 days after change is adopted. Further, 60 days’ notice is required in advance of any mid-plan-year change in benefits. |
| COBRA General Notice |
Group health plans covered by COBRA |
Must be provided within 90 days after beginning of coverage. May be included with enrollment materials. |
| Grandfathered Plan Notice |
Plans with “grandfathered” status under ACA |
Status must be publicized along with standard plan materials (e.g., SPD, open enrollment materials). Model notice available from DOL. |
| Notice of Patient Protections |
Group plans requiring designation of participating primary care provider |
Must be provided along with SPD or other benefits description. Model notice available from DOL. |
| HIPAA Privacy Notice |
ALL group health plans |
Separate rules cover self-insured and fully-insured plans. Sponsor provides notice if self-insured, but insurance carrier issues if fully-insured. Notice must be updated or a least publicized every 3 years. |
| HIPAA Special Enrollment Notice |
ALL group health plans |
Provides all participants with special enrollment rights under HIPAA at time of enrollment. |
| HIPAA Wellness Notice |
Group health plans with “contingent wellness plans” |
Employer-sponsors must provide a notice informing employees of an alternate way to qualify for the program’s reward; must be in all plan materials. |
| Wellness Notice – ADA |
Wellness programs collecting health information or conducting wellness exams |
Programs exercising either of those practices must comply with the ADA by providing notice to participants about how those data are collected, stored, and protected. Notice must be provided prior to any data being collected. |
