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The Wagner Law Group

The Wagner Law Group, A Professional Corporation, is a nationally recognized ERISA & employee benefits, estate planning, employment, labor & human resources practice. 

 

Established 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.

 

 

 

 

Contact Info

The Wagner Law Group

 

  Integrity | Excellence

  

Boston 

Tel: (617) 357-5200 

Fax: (617) 357-5250 

99 Summer Street 

13th Floor

Boston, MA 02110


Palm Beach Gardens 

Tel: (561) 293-3590
Fax: (561) 293-3591
7108 Fairway Drive
Suite 125
Palm Beach Gardens, FL 33418

   

Tampa

Tel: (813) 603-2959

Fax: (813) 603-2961

101 East Kennedy Boulevard

Suite 2140
Tampa, FL  33602 

 

San Francisco

Tel: (415) 625-0002

Fax: (415) 358-8300

300 Montgomery Street

Suite 600

San Francisco, CA 94104

 

St. Louis

Tel: (314) 236-0065

Fax: (314) 236-5743
100 South 4th Street, Suite 550
St. Louis, MO  63102 

 

www.wagnerlawgroup.com

 

 

 

 

June 3, 2016

 

 Health and Welfare Law Alert

 

 

 

Agencies Release New Summary of Benefits and Coverage Template

 

 

 

 

HHS, DOL 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 as follows:


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.

 

Uniform 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 information. 
  • Disclosures 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.
  • A 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.
  • Revised formatting, including:
    o Space savers to help plan sponsors meet the 4-page limit for SBCs.
    o Underlining of standard plan terms defined in the Uniform Glossary.
    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, 2017.


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 requirements.


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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This Newsletter is provided for information purposes by The Wagner Law Group to clients and others who may be interested in the subject matter, and may not be relied upon as specific legal advice.  This material is not to be construed as legal advice or legal opinions on specific facts. Under the Rules of the Supreme Judicial Court of Massachusetts, this material may be considered advertising.