Guidance issued jointly by the Departments of the Treasury (IRS), Labor (DOL) and Health and Human Services (HHS) in a fourth set of FAQs offers insight into what plan materials must bear notice of a health plan’s grandfathered status. A grandfathered health plan must include a statement in any plan materials provided to participants describing benefits under the plan, that the plan is a grandfathered health plan. This fourth set of FAQs clarifies that this notice need not be included on the explanation of benefits (EOB) documents issued by the plan in response to a claim for benefits, but that it should be included in any plan summaries, such as the summary plan description (SPD) or similar documents. No further guidance is available as to what other types of plan materials must contain the grandfathered plan disclosure. Have questions about grandfathered status, required disclosures or other health care reform topics? Contact Kristine Cienfuegos at 800-733-8621.
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