Insurers Likely Won’t Be Required To Use New SBC Templates Until 2017

In December 2014, the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (the Departments) proposed new rules regarding the Patient Protection and Affordable Care Act (ACA) required Summary of Benefits and Coverage (SBC). In addition, the Departments released new proposed SBC templates and other related documents. According to the recently released FAQs about Affordable Care Act Implementation (Part XXIV), the Departments believe that the new templates and related documents will not be effective until the start of the 2017 plan year.

Background. Under the ACA, group health plans and health insurers are required to meet the reporting and disclosure requirements of Public Health Service Act (PHSA) Sec. 2715, namely, to provide an SBC that accurately describes the benefits and coverage under the applicable plan or coverage. The SBC must be a concise summary (limited to four double-sided pages) of the key benefits and coverages provided through the health plan, the costs to the participant, lists of excluded services, and other significant conditions or limitations. Final regulations were issued in February 2012 and provide for 12 required content elements.

Effective dates. On December 30, 2014, the Departments issued proposed rules, as well as a new set of proposed SBC templates, instructions, an updated uniform glossary, and other materials. These materials were proposed to apply beginning September 1, 2015.

In the new FAQ, the Departments note that they 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 or after January 1, 2016. As for the SBC template and associated documents, the Departments are utilizing consumer testing and allowing the public and the National Association of Insurance Commissioners to provide further input before finalizing the templates and related documents. 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 or after January 1, 2017.

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