Guidance Issued on New Summary of Benefits and Coverage Document
Deadline Change, Formatting and Content Requirements
February 9th, the U.S. Departments of Labor and Health & Human
Services and the Internal Revenue Service issued final regulations with respect
to the new Summary of Benefits and Coverage (SBC) required to be distributed to
health plan participants under the Patient Protection and Affordable Care
Act. While there is still much to digest in the 150 pages of regulations,
the first and most important point to be made at the moment is that the
initial due date has been deferred from March 23rd to September 23rd.
is the SBC? It’s a new document designed to bring uniformity to health
plan summaries. Some have described it as “the benefit plan equivalent of
the standard food nutrition label” we are used to seeing on food packaging.
Some features of the SBC are:
of SBC’s will now be due on the first day of an open enrollment period
beginning after September 23rd for those who enroll (or
re-enroll) via open enrollment. For those who enroll outside of the “open
enrollment” window, it must be available as of the 1st day of the 1st
plan year beginning after September 23rd. In the future,
SBC’s will need to be delivered on the first day of open enrollment, within 90
days of enrollment for new participants, at least 60 days in advance of any
“mid-year” plan changes and within 7 business days of a participant’s request.
what does this mean for plans renewing in the fall? It’s complicated for
plans renewing on October 1 but will be more straightforward for future renewal
dates. For example:
For an October 1 renewal with an open
enrollment that begins September 1, the SBC will not be required until September
1, 2013. However, it must available as of October 1, 2012 for people
enrolling on or after that date for reasons other than open enrollment, such as
is still a great deal to sort out about the rules that will ultimately be
applied to the creation/distribution of the SBC: will the documents
prepared by carriers be “editable” is one question, and what are the deadlines
for insurance carriers to deliver SBC’s to plan sponsors is another. So…
more to follow. Summit will continue to monitor this topic and provide
updates as appropriate. In the meantime, if you have any questions or if
we can be of any assistance with any aspect of your benefit plans, please contact
a member of Summit Benefit Solutions Team.
The materials created through August 2011 are when the professionals of Summit Financial were with Ogilvie Security Advisors Corp. The professionals of Summit Financial have not been with Ogilvie Security Advisors Corp. since August 31, 2011 and have no further affiliation with that organization.