Posts Tagged: SBC

SBC Templates Delayed But Not Final Regulations

in Affordable Care Act, Health Benefits

The Agencies announced yesterday (click here for release) that the SBC final regulations will be published soon and will apply to plan years beginning on or after January 1, 2016.  However, the updated SBC templates will not be available until 2016, meaning that they won’t apply until plan years beginning on or after January 1, 2017. While this is welcome news and it means that SBC templates will not have to be updated for this year’s open enrollment – it doesn’t necessarily mean that there won’t be any changes for SBCs this year.  The Agencies made a special point of… Continue Reading

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