WorldatWork Responds to Proposed Rule in New Health Care Law

October 20, 2011 — WASHINGTON — WorldatWork submitted a letter responding to a request for comments on a proposed rule pertaining to the Summary of Benefits and Coverage (SBC) and the Uniform Glossary as outlined in the Patient Protection and Affordable Care Act (PPACA).

WorldatWork expressed concern that the proposed rule will create overwhelming complications for consumers, and that the proposed implementation date of March 2012 will be nearly impossible for employers to meet.

Specifically, WorldatWork expressed four main concerns: the onerous nature of the proposed rule, redundancies between ERISA compliance and the newly created SBCs, feasibility of implementation within the time frame proposed, and additional costs associated with elements of the SBC.

A growing body of research suggests that the abundance and complexity of benefits information can overwhelm consumers and create a significant non-price barrier to coverage. WorldatWork is concerned that the proposed rule will increase this barrier.

WorldatWork recommends that the final rule be clarified and simplified so that it can be better understood by both consumers and employers, and that the implementation date be moved to March 2013. These recommendations were included in a comment letter dated October 19, 2011, sent to the Employee Benefits Security Administration, Centers for Medicare & Medicaid Services, and the Internal Revenue Service.

About WorldatWork®: The Total Rewards Association

WorldatWork ( is a not-for-profit organization providing education, conferences and research focused on global human resources issues including compensation, benefits, work-life and integrated total rewards to attract, motivate and retain a talented workforce. Founded in 1955, WorldatWork has nearly 30,000 members in more than 100 countries. Its affiliate organization, WorldatWork Society of Certified Professionals®, is the certifying body for the prestigious Certified Compensation Professional® (CCP®), Certified Benefits Professional® (CBP), Global Remuneration Professional (GRP®), Work-Life Certified Professional™ (WLCP®), Certified Sales Compensation Professional™ (CSCP™), and Certified Executive Compensation Professional™ (CECP™). WorldatWork has offices in Scottsdale, Arizona, and Washington, D.C.

The WorldatWork group of registered marks includes: Alliance for Work-Life Progress® or AWLP®, workspan®, WorldatWork ® Journal, and Compensation Conundrum®.


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