Friday, March 9, 2012

BCBSNC provides update on PPACA Uniform Coverage Documents requirement

The government ruling for complying with the Uniform Coverage Documents (UCD) project has moved to September 23, 2012 (the original date was March 23, 2012).   The regulations of this ruling are broken into 3 requirements:
  • The Standardization and the Provision of the Summary of Benefits and Coverage (SBC)
  • The Standardization and the Provision of the Uniform Glossary
  • 60-Day Notice of Material Modification
Effective September 23, 2012, each Summary of Benefits and Coverage (SBC) must include:
  • A description of the coverage
  • Exceptions, reductions and limitations of coverage
  • Cost-sharing provisions of the coverage
  • Renewability and continuation of coverage provisions 
  • “Coverage Examples”
This SBC must be provided at initial and annual enrollment.  Here are the major changes in the final ruling:
  • Regulations apply beginning September 23, 2012
  • Health plans are no longer required to disclose the premium amount on the SBC 
  • There is some flexibility with the template.  In general, the required SBC format and instructions must be followed.  However, if a particular plan cannot reasonably be described consistent with the template and instructions, the insurer or employer must use its “best efforts” to describe the relevant plan terms and conditions while following the requirements as much as “reasonably possible”
  • Employers and insurers in the group market are allowed to combine the SBC with other consumer materials as long as the SBC is displayed at the beginning of the materials
  • Electronic delivery of SBCs will be permitted in some situations, as long as paper copies are made available on request
  • Health and Human Services will provide templates in alternative languages (Spanish, Chinese, Navaho and Tagalog)

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