Departments addresses application date of proposed SBC template changes

At the end of February, the Department of Labor (DOL) and Department of the Treasury requested comments on revisions to the Summary of Benefits and Coverage (SBC) template and associated documents. The DOL, in conjunction with the Department of Treasury and Department of Health and Human Services, has confirmed that health plans will be required to use the new SBC template and associated documents beginning on the first day of the first open enrollment period that begins on or after April 1, 2017, with respect to coverage for plan years beginning on or after that date.

Background. The Patient Protection and Affordable Care Act (ACA) (P.L. 111-148), under Sec. 1001(5), directs the Departments to develop standards for use by a group health plan and a health insurance issuer offering group or individual health insurance coverage in compiling and providing a SBC that “accurately describes the benefits and coverage under the applicable plan or coverage.” On June 16, 2015, the Departments published revised joint final regulations regarding the requirements for the SBC. Separately, on February 26, 2016, the Departments published a coordinated information collection request proposing a new SBC template and instructions, an updated uniform glossary, and other associated materials.

Implementation date. In recently-issued FAQs, the Departments noted that the public comment period for the proposed SBC template and associated documents closes on March 28, 2016. The plan is to review the comments expeditiously and finalize the new SBC template. Once finalized, the Departments intend that health plans and issuers that maintain an annual open enrollment period will be required to use the new SBC template and associated documents beginning on the first day of the first open enrollment period that begins on or after April 1, 2017 with respect to coverage for plan years (or, in the individual market, policy years) beginning on or after that date.

For plans and issuers that do not use an annual open enrollment period, the new SBC template and associated documents would be required beginning on the first day of the first plan year (or, in the individual market, policy year) that begins on or after April 1, 2017.

SOURCE: FAQs about Affordable Care Act Implementation (Part 30), March 11, 2016.

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