Friday, March 23, 2012

Agencies release FAQs on SBC requirement of health reform law

On March 19th, the Departments of Labor, Health and Human Services (HHS), and the Treasury (the Departments) released Part VIII of their FAQs about implementation of the health reform law. The FAQs specifically addresses the Summary of Benefits and Coverage (SBC) requirements.  The agencies explain that the aim of the FAQs is to explain some of the questions that have been raised so far, but acknowledge that further FAQs will also be released.

Some of the key points include:
  • the effective date of the SBC requirements remains as the first open enrollment period that begins on or after September 23, 2012 and the first plan year that begins on or after that date (for enrollments occuring outside of open enrollment)
  • SBCs must be provided at the same time open enrollment materials are distributed
  • SBCs may be provided to a participant on behalf of a beneficiary
  • SBCs will not be required for different plan features (meaning that different coverage tiers and different plan designs may be included in a single SBC), provided the appearance is understandable
For more information on the SBC requirements, please refer to the FAQs and our previous posts on this topic:

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