Posts Tagged: SBC

HHS Updates CLAS Requirements

in Affordable Care Act, Health Benefits

Have you ever noticed that EOBs are now five pages long?  I recently received one in the mail that needed it’s own table of contents.  One of the reasons is that the ACA requires non-grandfathered group health plans to provide  notices (such as EOBs and SBCs) in a culturally and linguistically appropriate manner, referred to as the CLAS requirements.    The regulations implementing this requirement also require non-grandfathered health plans to make certain accommodations for notices sent to an address in a county meeting a threshold percentage of people who are literate only in the same non-English language. This threshold percentage is set at 10… Continue Reading

Updated SBC Guidance Released

in Affordable Care Act

Yesterday a new model SBC and a new sample completed SBC were released, along with FAQs Part XIV which can be found here. As you may recall from the last open enrollment period, the Summary of Benefits and Coverage provides information to plan participants about plan design using a required format. The updated SBC is necessary because the template provided last year did not include information regarding whether the benefit option being described provides minimum essential coverage (MEC) or meets the minimum value (MV) requirements. As a reminder, MEC refers to the comprehensive medical coverage individuals must have to avoid… Continue Reading

SBC Reminder

in Affordable Care Act, Wellness Programs

I recently spoke at the ECFC meeting last week – with one of the major topics being SBCs. It is important to keep in mind that seperate SBCs will be needed for the following arrangements: 1. Stand-alone HRAs. 2. Integrated HRAs where the HRA is seperately administered (i.e., not administered by the insurer). 3. Employee Assistance Programs (EAPs) where the EAP is providing assessment or treatment. In these situations, significant revisions will be needed to the SBC template, so that the SBC works for these arrangements and is not misleading. However, you still need to retain the outline of the… Continue Reading

Updated SBC Guidance

in Affordable Care Act

As I noted during Friday’s post, the agencies announced additional SBC guidance will be forthcoming.  Ever coy about release dates, the agencies did not happen to say that the release date was right after our Friday meeting!  DOL released the updated guidance in the form of additional FAQs and updated SBC templates.  One of the more shocking issues addressed in this new guidance is relaxed electronic disclosure requirements.  Specifically, the updated guidance provides that SBCs may be provided electronically to participants and beneficiaries in connection with their online enrollment or online renewal of coverage under the plan. SBCs also may… Continue Reading

ABA Section of Taxation Meeting

in Affordable Care Act, Health Benefits

This morning we held our annual May meeting for the health and welfare subcommittee of the Section of Tax.  I want to thank all the IRS and Treasury people that attended the meeting – at one point I counted at least eight in attendance.  We discussed the usual suspects – SBCs, SPDs, PCOR fees, MEWAs – and a few other acronyms.  The most interesting item was by far the SBC rules.   There will be a lot of issues and headaches to work out for SBCs this summer and fall.  In this regard, there is an unofficial rumor that additional SBC… Continue Reading