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Tag: Summary of benefits and coverage

Implementing Health Reform: Provision Of Summary of Benefits and Coverage

One of the most important insurance reforms imposed by the Affordable Care Act is a requirement that insurers and self-insured group health plans make available to applicants and enrollees a Summary of Benefits and Coverage (SBC) that concisely, uniformly, and accurately describes health plans that applicants are considering or in which enrollees are enrolled. The SBC allows shoppers to compare side-by-side plans that they are considering purchasing, and also helps enrollees understand their coverage once they are enrolled.

The ACA required the Departments of Labor, Treasury, and Health and Human Services, which are charged with implementing the SBC requirements, to consult with a stakeholder group convened by the National Association of Insurance Commissioners in drafting the SBC rule. The original final SBC rulewas not published until 2012, after recommendations were received from that body.

When the 2012 SBC rule was published, however, and again in the months following its publication, the departments released a series of frequently asked question which generally provided plans and insurers flexibility in complying with the requirements of the rule. In December of 2014, the departments published a proposed rule (covered here) to modify the original rule.

The proposed rule contained provisions governing how insurers and group health plans were to make SBCs available, as well as changes to the content of the SBC itself — the SBC template and instructions and uniform glossary of coverage terms.

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.

Cosby Insurance Group Warrenton Health Insurance Broker and Agent

Agencies Issue Proposed Rule Amending Summary of Benefits and Coverage Requirements and Revising Templates, Instructions, and Uniform Glossary

On December 30, 2014, the Departments of Health and Human Services, Labor and Treasury (the “Agencies”) jointly published a proposed rule amending the current Summary of Benefits and Coverage (“SBC”) regulation. 79 Fed. Reg. 78578. At the same time, the Agencies revised the SBC template; the sample completed SBC; the instructions for
completing the SBC applicable to group coverage and to individual coverage; the “Why This Matters” language template; the Coverage Examples; and the Uniform Glossary.

Comments are requested by March 2, 2015 on the proposed rule and the revised documents.

What Actions You Should Take

Group health plans and health insurance issuers should carefully review the proposed modifications to the SBC to determine how those modifications will change the plan or issuer’s compliance efforts. Note, particularly, that the Agencies propose to require plans and issuers to use these new templates for this fall’s open enrollment. As with the previous final SBC rule, given the complexity of the rule, and the potential for civil penalties, it is
important that plan sponsors and health insurance issuers to carefully evaluate the time and resources necessary to comply with the rule.

Comments are due March 2, so there is still time to share any thoughts or concerns you have with the proposed rule with the Agencies.

I. Background

The Patient Protection and Affordable Care Act (“ACA”) added section 2715 to the Public Health Service Act (“PHSA”) which requires group health plans and health plan issuers to compile and provide an SBC that “accurately describes the benefits and coverage under the applicable plan and coverage.”
The SBC requirement applies to insured and self-funded ERISA group health plans, including grandfathered plans, as well as to non-ERISA group health plans and individual health insurance coverage.

The SBC must follow a uniform format which includes a series of content requirements such as: uniform standard
definitions of medical and health coverage terms; a description of the coverage including the cost sharing
requirements (i.e. deductibles, coinsurance, and copayments); and information regarding any exceptions, reductions,
or limitations under the coverage. On August 22, 2011, the Agencies issued proposed regulations on 76 Fed. Reg.
52442 (Aug. 22, 2011); 76 Fed. Reg. 52475 (Aug. 22, 2011). The final regulations were published in the Federal
Register on February 14, 2012 and were effective on April 16, 2012. A summary of those final regulations is available at http://www.groom.com/resources-653.html.

Read the full article here.

Contact Steven G. Cosby, MHSA with questions or to request more information and to schedule a healthcare plan evaluation, savings analysis or group plan solution for your company.

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