New Template Generally Expected to Apply to Plan Years Beginning On or After April 1, 2017

A new Affordable Care Act (ACA) Implementation FAQ regarding the applicable date for using the new proposed summary of benefits and coverage (SBC) template and associated documents is now available.

Background
Under the ACA, group health plans and health insurance issuers are generally required to provide a written SBC to plan participants and beneficiaries at specified times during the enrollment process and upon request.

While final regulations to amend the existing rules related to the SBC notice requirements were previously released in June of 2015, at that time federal agencies announced that a new SBC template and associated documents would be finalized separately. On February 26, 2016, the new proposed SBC template and instructions, an updated uniform glossary, and other associated materials were released.

New FAQ
The intended implementation date for SBCs using the new proposed template and associated documents is as follows:

  • Health plans and issuers that maintain an annual open enrollment period will be required to use the new SBC template and associated documents beginning on the first day of the first open enrollment period that begins on or after April 1, 2017 with respect to coverage for plan years beginning on or after that date.
  • For health plans and issuers that do not use an annual open enrollment period, the new proposed SBC template and associated documents would be required beginning on the first day of the first plan year that begins on or after April 1, 2017.

Visit the U.S. Department of Labor’s webpage on the SBC and Uniform Glossary for the latest updates and to access all available templates.

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