Employer Sponsored Group Health Plans to Provide Benefits Summary

Pillsbury

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09.08.11

On August 22, the Departments of the Treasury, Labor, and Health and Human Services (the “Agencies”) published long-awaited proposed regulations on the new Summary of Benefits and Coverage (“SBC”) that all group health plans (including grandfathered plans) will be required to distribute, effective March 23, 2012. Plan administrators must deliver this four-page (front and back) SBC to plan participants in addition to already-required disclosures such as the summary plan description. These proposed regulations provide standards that will govern the SBC, including who provides and receives the SBC, when the SBC must be provided, and how the SBC must be formatted and distributed. This client alert summarizes the proposed requirements for sponsors of group health plans. Plan administrators and insurance providers of group health plans should review these requirements now to prepare for timely provision of the SBC.

The Patient Protection and Affordable Care Act of 2010 (“PPACA”) requires that all group health plans (and their insurance providers) must distribute an SBC to applicants, participants, and beneficiaries that accurately describes the benefits and coverage available under the plan. This mandate is in alignment with the current administration’s goal of making healthcare choices easier for consumers by providing better access to information comparing the most important features of available healthcare options. The proposed regulations develop the standards for how, when, and to whom the SBC will be provided.¹ In addition, the Agencies simultaneously published an SBC draft template and sample language, instructions for completing the SBC, and the uniform glossary of terms that must be made available with the SBC.²

The SBC requirement is statutorily effective March 23, 2012. Unless this effective date is extended in the final regulations, the SBC requirement will apply to all enrollments (including annual and special enrollments) and requests for the SBC that occur as of March 23, 2012.

To view the proposed regulations see http://www.gpo.gov/fdsys/pkg/FR-2011-08-22/pdf/2011-21193.pdf.
To view the SBC template, uniform glossary and related materials see http://www.gpo.gov/fdsys/pkg/FR-2011-08-22/pdf/2011-21192.pdf. Note, the draft template, uniform glossary, and related materials were prepared by the National Association of Insurance Commissioners and proposed by the Agencies without change. Accordingly, these materials were drafted primarily for use by insured health plans. The Agencies have requested comments on how to modify these materials for other types of health plans, such as self-insured plans.

Downloads: Health Care Reform Update: Employer Sponsored Group Health Plans Must Provide New Summary of Benefits and Coverage

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