Proposed Rule Under Health Care Reform Regarding Summary of Benefits and Coverage May Be Delayed

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On August 22, 2011, the Departments of Health and Human Services, Labor and Treasury issued a proposed rule under the Patient Protection and Affordable Care Act (“PPACA” or the “Act”) that mandates group health plans and health insurance issuers to provide participants with a uniform summary of benefits and coverage (“Summary”). The effective date for the proposed rule is presently March 23, 2012. On November 17, 2011, the Department of Health and Human Services posted a statement on its website advising that the proposed rule may be delayed.