New SBC Template Generally Expected to Apply to Plan Years Beginning On or After April 1, 2017

A new Affordable Care Act (ACA) Implementation FAQ regarding the applicable date for using the new proposed summary of benefits and coverage (SBC) template and associated documents is now available.

Under ACA, group health plans and health insurance issuers are generally required to provide a written SBC to plan participants and beneficiaries at specified times during the enrollment process and upon request.

While final regulations to amend the existing rules related to the SBC notice requirements were previously released in June of 2015, at that time federal agencies announced that a new SBC template and associated documents would be finalized separately. On February 26, 2016, the new proposed SBC template and instructions, an updated uniform glossary, and other associated materials were released.

New FAQ
The intended implementation date for SBCs using the new proposed template and associated documents is as follows:
 
  • Health plans and issuers that maintain an annual open enrollment period will be required to use the new SBC template and associated documents beginning on the first day of the first open enrollment period that begins on or after April 1, 2017 with respect to coverage for plan years beginning on or after that date.
     
  • For health plans and issuers that do not use an annual open enrollment period, the new proposed SBC template and associated documents would be required beginning on the first day of the first plan year that begins on or after April 1, 2017.

 

Visit the U.S. Department of Labor's webpage on the SBC and Uniform Glossary for the latest updates and to access all available templates.


 

This Health Care Reform Update is provided by HR 360, Inc. to IPS Advisors and its clients.
 
The information and materials herein are provided for general information purposes only and are not intended to constitute legal or other advice or opinions on any specific matters and are not intended to replace the advice of a qualified attorney, plan provider or other professional advisor. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy. In accordance with IRS Circular 230, this communication is not intended or written to be used, and cannot be used as or considered a 'covered opinion' or other written tax advice and should not be relied upon for any purpose other than its intended purpose.

 

The information provided is for educational purposes only. This information is from sources we believe to be reliable, but we cannot guarantee or represent that it is accurate or complete. The opinions are those of the writer, and the opinions and information presented are subject to change without notice.

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