Recently, 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.
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.
What You Need To Know
- The Departments intend to finalize changes to the regulations in the near future, which are intended to apply in connection with coverage that would renew or begin on the first day of the first plan year - or, in the individual market, policy year - that begins on or after January 1, 2016, including open season periods that occur in the Fall of 2015 for coverage beginning on or after January 1, 2016.
- The Departments anticipate the new template and associated documents will be finalized by January 2016 and will apply to coverage that would renew or begin on the first day of the first plan year - or, in the individual market, policy year - that begins on or after January 1, 2017, including open season periods that occur in the Fall of 2016 for coverage beginning on or after January 1, 2017.
- 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 include, but are not limited to, the length of the SBC be a mandated four double-sided pages.
Good news! 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.
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 practice vigilance in staying current with the latest impending changes to the SBC template to ensure SBC compliance.