Friday, August 19, 2011

HHS announces proposed rules for uniform benefit summaries

On Wednesday August 17th, HHS released a Notice of Proposed Rulemaking for uniform benefit summaries as required by the Affordable Care Act (ACA).  HHS has adopted the format proposed by the NAIC for the standardized Summary of Benefits and Coverage.  Accoding to ACA, the Summary of Benefits and Coverage must include the following four components:
  • A four-page Benefit Summary (double sided)

  • Medical Scenarios called "Coverage Examples" for maternity, breast cancer treatment and managing diabetes

  • A standard glossary of medical and insurance terms

  • A phone number and website where individuals can get additional information including documents such as Certificates, Summary Plan Descriptions (SPDs) and policies

The new standardized summaries must be provided beginning with individuals enrolling in a medical plan on or after March 23, 2012.  This provision applies to individual and employer-sponsored medical plans, regardless of grandfathered status or funding.  For fully-insured plans, the insurer is responsible for producing and distributing the summaries.  For self-insured plans, the employer is responsible.

People enrolled in a health plan must be notified of any significant changes to the terms of coverage reflected in the Summary of Benefits and Coverage at least 60 days prior to the effective date of the change. This timing applies only to changes that become effective during the plan or policy year but not to changes at renewal (the start of the new plan or policy year).

Summaries are required to be provided both before and after enrollment and may be delived in paper and/or electronic format.  The penalty for willful non-compliance is up to $1,000 per enrollee.

For more information, please view Cigna's Informed on Reform briefing on this topic.

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