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Final Summary of Benefits and Coverage Regulations

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The long awaited regulations clarifying group health plan requirements for the Summary of Benefits and Coverage (SBC) have arrived. As you may recall, these regulations are contained in the Affordable Care Act (ACA). The IRS, Department of Labor, and Health and Human Services agencies issued the final regulations. Here’s the skinny…

Key Date:  September 23, 2012

This is the effective date for the following SBC requirements:

Open Enrollment

Communication requirements for participants during annual enrollment take effect for open enrollment periods beginning on or after September 23, 2012.

Other than Open Enrollment

Communication requirements for employees who enroll for group health plan coverage outside of open enrollment (e.g., new hires and HIPAA special enrollees) take effect on the first day of the plan year that begins on or after September 23, 2012.

Samples and Templates

The agencies have published new simplified samples and templates for developing an SBC. Check them out: http://www.dol.gov/ebsa/healthreform/.

Responsibilities

As before, the regulations confirm the following responsibilities:

Fully-insured Group Health Plans

The insurance carrier must produce and provide a valid SBC to employers who offer group health plans.

Self-insured Group Health Plans

An employer offering a group health plan is responsible for producing and delivering the SBC. Firms that help employers administer self-funded plans, however, will likely assist in the development of the SBCs.

What Is the Summary of Benefits and Coverage (SBC)?

The SBC is a communication that describes a medical plan’s key features and costs to help employees understand their benefit choices and to compare plans on an apples-to-apples basis. The SBC must also include a glossary of plan terms and examples of how the medical plan(s) cover health expenses.