Posts Tagged: SBC

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

Additional SBC Guidance

in Affordable Care Act

This afternoon the agencies released additional SBC guidance aimed at easing the compliance burden for group health plans.  Some of the key highlights of this new guidance include:   1.  Good Faith Standard.  Rather than delaying the requirements for one year, the agencies adopted a good faith compliance standard for 2013.   2.  Dependent Tiers.  As noted in our prior Legal Alert, the final regulations were unclear regarding whether an SBC was required for each dependent tier.  The new guidance confirmed that a separate SBC is not required for each dependent tier.   3.  SBCs Distributed with Open Enrollment Materials. … Continue Reading