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.
The Total Rewards Association
WorldatWork (http://www.worldatwork.org) 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. WorldatWork ® Journal, and Compensation Conundrum®.
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