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 Health Reform Status

On February 14th, three federal agencies issued final regulations concerning the "Summary of Benefits and Coverage" (SBC) which will be required for group plans after September 22, 2012. The

final regulations vary from the proposed rule in several important aspects and will impose onemployers and insurers new notice obligations. The final rule also imposes the 60 day advance notice

requirement before plan changes can take effect. In addition, guidance has been issued on the W-2reporting requirements, a notice has been promulgated on the employer mandate, and health plans will pay a tax this year. 

• Which plans are required to comply with the SBC Rule, which are not;
• Responsibility for the SBC-employer; insurer or both?
• The 60 day advance notice of change rule-what is a change? When is notice not required?
• Design, distribution and content of the SBC; who gets them? When? What must they say?
• W-2 Reporting; When required? Plans affected? Computing the value of coverage.
• The 2012 Health Plan Tax-how much? Who pays? When?
• Health Care-the State of the Connecticut Health Care Exchange; 

Robert Noonan
Employment Law & Human Resources Solutions 

Robert D. Noonan is an attorney and founder of Robert Noonan and Associates\ EmpACTS of New England - a legal services and human resources consulting firm.  

The firm concentrates its practice in the representation of employers in the areas of labor and employment law, including claims of discrimination and harassment based on sex, age, race, disability, national origin, religion; retaliation claims; wage-and-hour violations; contract claims; and claims under ERISA (Employee Retirement Income Security Act).  The firm advises more than 8,000 Connecticut employers and several trade associations on employer-employee issues.

The firm places emphasis on prevention and problem solving by advising employers on an ongoing basis. The firm advises employers on day-to-day employee related issues ranging from simple final paycheck questions to more complex employee misconduct investigations.  The firm drafts employment, severance, and non-compete agreements; handles compensation and benefits issues, including bonuses, commissions, stock and option awards; and counsels on family/medical leaves, discrimination, sexual harassment, and other disciplinary and termination issues.

While clients are often most advantaged by prevention and constructive solutions that minimize costs, the firm defensively litigates on behalf of employers in administrative proceedings (such as CHRO, EEOC and Department of Labor), arbitration's, and actions in federal and state courts.