New FAQ on Summary of Benefits and Coverage Requirements

April 21, 2015 by in category Affordable Care Act with 0 and 0

FAQ Clarifies When Proposed Rules & New SBC Templates Will Be Finalized

A new FAQ prepared jointly by the U.S. Departments of Labor, Health and Human Services, and the Treasury clarify when the Departments intend to finalize previously issued proposed regulations on the summary of benefits and coverage (SBC) notice requirements under Health Care Reform, including revisions to the SBC template and associated documents.

Background
Final regulations on the SBC notice requirements were published in 2012, after which the Departments released six sets of FAQs regarding implementation of the SBC requirements. Proposed rules to amend the final regulations were subsequently released in December 2014 in response to public feedback. Contemporaneously with the proposed rules, the Departments also published a new set of proposed SBC templates, instructions, an updated uniform glossary, and other materials.

New FAQ
The Departments generally expect to finalize and apply the proposed regulations in connection with coverage that would renew or begin on the first day of the first plan year that begins on or after January 1, 2016 (including open season periods that occur in the fall of 2015 for coverage beginning on or after January 1, 2016).

The Departments also are expected to utilize consumer testing and offer an opportunity for public feedback before finalizing revisions to the SBC template and associated documents. The Departments generally anticipate that the new template and associated documents will be finalized by January 2016 and will apply to coverage that would renew or begin on the first day of the first plan year that begins on or after January 1, 2017 (including open season periods that occur in the fall of 2016 for coverage beginning on or after January 1, 2017).

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