Under the Affordable Care Act, group health plans and issuers are required to provide a Summary of Benefits and Coverage (SBC) document to applicants and enrollees.
To help ensure that the SBC document truly makes it easier for consumers to access important health care information and understand their plan options, a set of proposed regulations was released on December 22, 2014. The proposed regulations also seek to provide clarified guidance regarding distribution of the SBC. Here is a brief overview of the proposed regulations:
- The SBC template will be shortened by removing information that is not required by the ACA. The sample completed template for a standard group health plan would be shortened from four double-sided pages to two and a half double-sided pages.
- The glossary would be updated: some definitions may be revised or removed, while new definitions regarding important insurance or medical concepts may be added.
- The “Coverage Examples” section would be modified; for example, a new example regarding a food fracture with an Emergency Room Visit would be added.
- If the plan sponsor is negotiating coverage terms after an application has been filed and the information that is required to be in the SBC changes, the plan or issuer is not required to provide an updated SBC (unless an updated SBC is requested) until the first day of coverage
- To prevent unnecessary duplication, new rules would be implemented regarding a number of scenarios. This includes binding contracts where another party assumes responsibility to provide the SBC. Also, the new rules would address the situation when a group health plan uses two or more insurance products provided by separate issuers to insure benefits with respect to a single group health plan.
Please stay tuned to CBG Benefits for additional information on these proposed regulations. If these regulations are finalized, it is expected that the new requirements for the SBC and uniform glossary would apply to coverage that begins on or after Sept. 1, 2015.
If you have any questions in the meantime, please contact CBG Benefits at 781-759-1222.