The Wagner Law Group
Wagner Law Group, A Professional Corporation, is a nationally
recognized ERISA & employee benefits, estate planning,
employment, labor & human resources practice.
in 1996, The Wagner Law Group has 22 attorneys engaged
exclusively in employee benefits, estate planning and
employment law. Six of our attorneys are AV rated by
Martindale-Hubbell as having very high to preeminent legal abilities
and ethical standards. The firm is among the largest ERISA boutiques
in the country. Our practice is national in scope, with clients in
more than 40 states and several foreign countries.
Wagner Law Group
Fax: (561) 293-3591
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Tampa, FL 33602
Francisco, CA 94104
100 South 4th Street, Suite 550
St. Louis, MO 63102
June 3, 2016
Health and Welfare Law
Agencies Release New Summary
of Benefits and Coverage Template
and IRS have released an updated Summary of Benefits and Coverage
("SBC") template and Uniform Glossary. Changes include an
additional coverage example and uniform definitions to increase
consumers' understanding of their health coverage.
Background. The Affordable Care Act
("ACA") requires group health plans and issuers to provide
consumers with a brief summary, or SBC, describing plan coverage and
cost-sharing responsibilities for the consumer. The SBC must follow a
uniform format and contain specified information.
The agencies have created a revised template SBC for group health
plan sponsors and issuers to use to satisfy the SBC requirements.
Revised SBC. Changes to the SBC template are
Coverage Examples. The SBC template includes a standardized
health plan comparison tool for consumers, called coverage examples.
The prior SBC template included coverage examples for pregnancy and
type 2 diabetes. The revised SBC template includes a third coverage
example involving a simple fracture treated in an emergency room.
Glossary. Plan sponsors and
issuers are required to provide consumers with a glossary of terms
commonly used in the group health plan coverage realm (e.g.,
"deductible"). The agencies have added required definitions
to the Uniform Glossary and have authorized group health plan sponsors
and issuers to hyperlink SBC terms to a glossary maintained by HHS.
Template Changes. The revised SBC template includes:
- A simple
explanation of what an SBC is and where consumers can find more
regarding minimum essential coverage, minimum value, and
language access services.
- A statement
that copayments for certain services may not be included in the
plan's out-of-pocket limits.
description of deductibles and how family members must meet
their own individual deductibles before the overall family
deductible limit is met and what services are covered before the
deductibles are met.
o Space savers to help plan sponsors meet the 4-page limit
o Underlining of standard plan terms defined in the Uniform
o Deletion of the explanation for the coverage examples.
o Adjustments to the required language.
Effective Dates. Plan sponsors that offer an annual open
enrollment period must provide the new SBC template starting on the
first day of the first open enrollment period that commences on or
after April 1, 2017. Plans without annual open enrollment
periods must begin to provide the new SBC template starting on the
first day of the first plan year that commences on or after April 1,
Takeaway for Employers. The changes to the SBC
template are numerous. Accordingly, employers are advised to
carefully review the agencies' modifications to the SBC template to
determine what revisions are required to their current SBCs.
Where third party administrators are responsible for preparing the
SBC for the group health plan, employers should confirm that such
SBCs are in compliance with the agencies' revised SBC template
Additional information regarding the ACA's SBC requirements is
accessible at: https://www.dol.gov/ebsa/healthreform/regulations/summaryofbenefits.html#proposed
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