Expert reminds calendar year plans to implement new SBC requirements during this year’s open enrollment

While “not a lot has changed from last year, from a compliance standpoint, when it comes to open enrollment,” the new Summary of Benefits and Coverage (SBC) template and uniform glossary need to be implemented during this year’s open enrollment for calendar year plans, according to Mike Sinkeldam, a principal for Mercer’s Health and Benefits practice. At a recent Mercer webinar, he reminded plan sponsors that “2018 will be the first plan year that we have to use the new template.”


The Patient Protection and Affordable Care Act (ACA) 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 April 6, 2016, the Department of Labor, IRS, and the Department of Health and Human Services released updated versions of the SBC template and the uniform glossary. Health plans are 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.

Open enrollment.

“Open enrollment is always a good opportunity to communicate what is required under ERISA and the ACA,” said Sinkeldam. “This is the time where employees will be most interested in reading about what is happening to their benefits.”

Several key enhancements have been made to the SBC template and uniform glossary for the 2018 plan year. The improvements include an additional coverage example and language and terms to improve consumers’ understanding of their health coverage. In addition, changes have been made to the SBC template that will improve readability for consumers.

SOURCE: Mercer webinar, Best Practices for Open Enrollment.
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