The "eagerly-awaited" guidelines regarding the uniform summary of benefits and coverage (SBC) required by Patient Protection and Affordable Care Act have finally been released.

Comments are being invited until Oct. 21, 2011, with implementation anticipated by March 23, 2012, the two-year anniversary of PPACA's passage. This is not just the first step in the direction of increasing uniformity in the structure and communication of benefit plans.

You've probably heard of the "guard-railing" effect of health reform legislation on benefits packages which has employers concerned about plans being too rich (thereby triggering the excise tax in 2018) or too skinny (and possibly triggering shared responsibility penalties in 2014). Also, don't be surprised to see some plans begin to morph into something resembling the tiers of benefits expected to be offered in the state insurance exchanges, also in 2014.

I don't think we're teetering on the brink of an imminent "one size fits all" benefits landscape. But, for those employers who view their benefits programs as key differentiators in the battle to attract and retain top talent, advisers will need to keep looking for ways to help clients make sure their benefits continue to stand out from a crowd that will start to look a little more homogenous than it ever has before.

What do you think? Share in the comments. 

Lane is principal at Mercer in Washington, DC. He can be reached at or 202-331-5222.

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