SBC-template-change-2015Earlier this year, the Department of Labor (DOL) announced that the new Summary of Benefits and Coverage (SBC) template and related documents, published in proposed regulations on December 22, 2014, are delayed until 2016. However, some changes to the regulation are in effect beginning September 1, 2015.

Earlier this year, the DOL, Health and Human Services (HHS) and the Treasury published final regulations on the SBC and uniform glossary requirement under the Affordable Care Act (ACA). These changes include streamlining content – adding information useful to consumers.

The ACA requires group health plans and health insurers to provide SBCs to participants and beneficiaries when they first enroll in coverage, during open enrollment, and on other specified occasions. The primary objective of the SBC is to help participants easily compare coverage options and better understand their health benefits. 

Additionally, the ACA requires group health plans and health insurers to provide SBCs to participants and beneficiaries when they first enroll in coverage, during open enrollment, and on other specified occasions. The primary objective of the SBC is to help participants easily compare coverage options and better understand their health benefits.

SBC Template Changes: What You Need To Know

09.08.sbcsampleProposed regulations took effect on September 1, 2015 for plan years beginning on or after January 1, 2016:

  • The ACA limits the length of the SBC to four pages, but the 2012 regulations interpret this requirement to be four double-sided pages. The final regulations retain this interpretation, allowing the SBC to be four double-sided pages.
  • Some plans and issuers have expressed concern regarding the difficulty of including all of the required information in four pages - even double-sided pages.
  • The final regulations provide that when the Departments finalize the new template and associated documents (separate from the final regulations), they will address specific issues related to fitting all the required information into the four-page template.
  • The final regulations also clarify that all plans and issuers must include contact information for questions and a Web address where a copy of the actual individual coverage policy or group certificate of coverage can be reviewed and obtained.
  • Health insurance issuers must provide online access to a copy of the group certificate of coverage or individual coverage policy for each plan. These documents must be made publicly available to all potential consumers – individuals and employers – prior to when they apply for individual or group coverage, so they are clearly informed about what a plan will and will not offer. 

Issuers must provide the SBC upon request before application for coverage.

If an entity or individual requests a copy of the SBC before applying for coverage and the issuer provides the SBC at that time, the requirement to provide an SBC upon application is deemed satisfied, and the issuer is not required to automatically provide another SBC upon application to the same entity or individual, as long as there has been no change to the information required to be in the SBC.

What’s Delayed Until 2016?

Per the FAQ, the new SBC template will go through consumer testing. The DOL anticipates that the document will be finalized in January 2016, and will apply to 2017 coverage.

  • Use will likely begin during fall 2016 open enrollment for plan years beginning on or after January 1, 2017.
  • Expected changes to the template include, but are not limited to:
  • Updated claims/pricing data for the coverage example calculator.
  • New minimum essential coverage and minimum value information.
  • Issuer website for specific policy or group certificate of coverage information.
  • Uniform glossary revisions.
  • Removal of annual limits for essential health benefits (EHBs) information.
Streamlining Information

Changes to the SBC template are aimed at reducing duplication and enforcing a streamlined delivery of required information, packaged in a compact, four-page template. Plan sponsors should ensure that their SBCs for Fall 2015 open enrollment are up to date in light of these final regulations — a task that will be controllable and attainable for those that updated their SBCs to account for impending changes.

For more information, visit DOL’s ACA Regulations and Guidance.