Human Resources
Thought Leadership

Aon Hewitt Submits Comments on Summary of Benefits and Coverage

On October 20, 2011, Aon Hewitt submitted comments to the Departments of Labor (DOL), Treasury, and Health and Human Services on the proposed rule related to the Summary of Benefits and Coverage, as part of the Patient Protection and Affordable Care Act (Affordable Care Act). The proposed rule was published in the Federal Registeron August 22, 2011.

In the comment letter, Aon Hewitt offers the following recommendations:

  • Delay the effective date;
  • Clarify covered plans;
  • Promote electronic delivery concurrent with enrollment;
  • Eliminate the requirement to acknowledge receipt;
  • Allow flexibility in providing the disclosures;
  • Eliminate premium cost information;
  • Adopt the DOL's Summary of Plan Description (SPD) Guidelines on "Culturally and Linguistically Appropriate;"
  • Simplify automatic delivery rules; and
  • Simplify coverage examples.

The full comment letter is available below.

Aon Hewitt Submits Comments on Summary of Benefits and Coverage