Last December, we distributed a Group Health & Welfare Plan Disclosure Checklist to assist clients with their various disclosure obligations under ERISA, COBRA, HIPAA, ACA, and other assorted federal laws. For those of you familiar with that checklist, it outlines the basics with respect to these disclosure obligations - who, what, when, and how - for group health plans sponsored by private sector employers.
In order to extend this compliance tool to our public sector (governmental) clients, we have revised the Disclosure Checklist to include a column that specifies which disclosure obligations (and, in some cases, special considerations) apply to governmental plans.
A footnote has also been added to the Disclosure Checklist to clarify the group size to which the "small group" column applies.
We hope these updates will be helpful to you and your clients. You may also refer to the Group Health and Welfare Disclosure Checklist Review Presentation from February for details about the Disclosure Checklist.
