Federal regulators will maintain an overall emphasis on cooperation with plan sponsors over Summary of Benefit Coverage (SBC) duties, rather than penalty enforcement for plan years beginning in 2014 and 2015.
As long as plan sponsors have worked "diligently and in good faith" to fulfill SBC duties on their own. Penalties will apply only in the case of "willful' failure to provide required SBC information.
Source: DOL Q & A, May 2014.
