Has the DOL and IRS waived the requirement that summaries of material modification be issued within 60 days?

Posted by Bonita Hatchett-Bodle

May 1, 2020 2:09:04 PM

Yes. Under the Public Health Services Act (PHSA), if a plan makes a material modification, as defined under ERISA, in any of the terms of the plan or coverage that would affect the content of the Summary of Benefits and Coverage (SBC) that is not reflected in the most recently provided SBC, and that occurs other than in connection with a renewal or reissuance of coverage, the plan or issuer must provide notice of the modification to enrollees not later than 60 days prior to the date on which the modification will become effective.

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Topics: Summary of Material Modifications, FFCRA, CARES Act