WASHINGTON—A proposed regulation that would implement a requirement that employers issue a health care benefit statement to employees raises more questions than it answers, experts say.

The heart of the proposed regulation involves a multipage summary of health care benefits and coverage that is mandated by the federal health care reform law. The Internal Revenue Service and the Health and Human Services and Labor departments proposed the rule last week.

The statement, which employers and plan administrators would have to follow assuming the regulation is not altered, would have to be provided for every plan that an employer offers by March 23, 2012.

That is two years after enactment of the Patient Protection and Affordable Care Act.

One part of the Summary of Benefits and Coverage would be divided into three columns. One column, “Important Questions,” would include:

• What is the premium?

• What is the overall deductible?

• Are there other deductibles for specific services?

• Is there an out-of-pocket limit on my expenses?

• What is not included in the out-of-pocket limit?

In an adjacent column, “Answers,” responses to the questions would have to be provided. A third column, with the heading “Why this Matters,” would include required additional detail.

In another section of the statement, employers would have to give examples of how coverage would apply in three specific situations: having a baby, treating breast cancer and managing diabetes. The government is considering adding three more unspecified examples.

For each example, employers would have to use a dollar figure dictated by the government on the amount that would be owed to providers. In the case of having a baby, the figure in the regulation is $10,000.

Then, the employer would fill in how much the employee would pay and how much the plan would pay.

Other information, also using government-supplied figures, would include sample care costs. For having a baby, cost information would include the first office visit, radiology, laboratory tests, and hospital charges for mother and child.

At the bottom of the example, under the heading, “You Pay,” dollar figures would have to be provided on deductibles, copayments, coinsurance, and limits or exclusions.

Benefit experts say the proposed regulations raise numerous questions.

“There is just not enough here to tell us what to do,” said Rich Stover, a principal at Buck Consultants L.L.C. in Secaucus, N.J.

For instance, the examples make no distinction between costs employees would pay depending on whether the service was delivered in or out of network, said Gretchen Young, senior vp-health policy with the ERISA Industry Committee in Washington.

In addition, requiring employers to use government-set figures, which presumably would be national averages, could end up confusing employees if a particular employer's costs are different, which is likely since costs vary greatly across the country.

“This could end up confusing plan participants,” said Jennifer Henrikson, senior counsel with Aon Hewitt Inc. in Lincolnshire, Ill.

Yet another source of confusion are some “Important Questions” and “Answers” that would have to be provided. A seemingly simple question, “What is the overall deductible?” could be difficult to answer in situations where employers, for example, link the amount of the deductible to employee compensation, Mr. Stover said. Still, the proposed regulations could change significantly.

Regulators have made it very clear that they want public comment, said Kelly Traw, a principal with Mercer L.L.C. in Washington.

Oct. 21 is the deadline for comments on the proposal, which is available online at www.ofr.gov/OFRUpload/OFR Data/2011-21193_PI.pdf.