On June 16, 2015, the Departments of Health and Human Services, Labor and Treasury (the “Agencies”) jointly published a final rule amending current guidance governing the Summary of Benefits and Coverage (“SBCs”) (“Final Rule”). 80 Fed. Reg. 34292. This rule finalizes the guidance issued in the Agencies’ proposed rule dated December 30, 2014 (“Proposed Rule”).
While the rule primarily codified previous guidance and FAQs related to SBCs, and we expect that the biggest changes related to SBCs will be seen when the Agencies finalize the template and instructions, issuers in particular are subject to new requirements under the rule, including a requirement to post the actual certificates of coverage. Entities that rely upon others to provide the SBC now also have a duty to monitor that performance. Please see the attached memo for further information.
What Actions You Should Take
While the rule primarily codified previous guidance and FAQs related to SBCs, and we expect that the biggest changes related to SBCs will be seen when the Agencies finalize the template and instructions, issuers in particular are subject to new requirements under the rule, including a requirement to post the actual certificates of coverage. Entities that rely upon others to provide the SBC now also have a duty to monitor that performance.
Read the full report here.
Contact Steven G. Cosby, MHSA, Group Health Insurance Broker and Agent with Cosby Insurance Group, with questions or to request more information and to schedule a healthcare plan evaluation, savings analysis or group plan solution for your company.
