Department of Labor (DOL) FAQ Regarding Proposed Changes to the SBC: Change in Compliance Date
In April of 2015, the DOL released an FAQ regarding the proposed Summary of Benefits and Coverage (SBC) rules, which specifically addresses when the departments intend to finalize the changes to this rule.
What does the FAQ say?
Final revisions to the SBC template and associated documents, including any changes to the uniform glossary, will be finalized by January 2016. Plans will be required to comply with these changes as of the first plan year on or after April 1, 2017.* This means that plans that begin in April 2017 or after will need to make sure their SBCs comply with the final regulations prior to their open enrollment period.
*On March 11, 2016, the DOL extended the applicability date from the first plan year on or after January 1, 2017 to April 1, 2017.
To whom does this apply?
All group health plans and insurers that must comply with the Affordable Care Act, regardless of ERISA status or grandfathered status, must provide an SBC to their members and individuals who are considering enrollment into the health plan.
What are the proposed changes?
The key proposed changes to the SBC document are as follows:
- A third example of coverage will be added to include a simple foot fracture with an emergency room visit; and
- The overall look of the template will be more streamlined, removing information that has been deemed not useful. The document will be shortened from four double-sided pages (eight pages total) to just two and one-half double-sided pages (five pages total).
The uniform glossary may also see changes, which would include removing references to pre-existing conditions and annual limits on essential health benefits. The proposed rules make additions to the glossary, which include definitions for claim, individual responsibility requirement, minimum value and cost-sharing reductions. The glossary will increase from four pages to six.
If you have any questions, please contact your client solutions team.
Compliance Corner is being provided as an informational tool. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this publication and any attachments, Meritain Health is not exercising discretionary authority over the plan and is not assuming a plan fiduciary role, nor is Meritain Health providing legal advice.