As March comes to a close, health plans and issuers are reminded they must now use the new Summary of Benefits and Coverage (SBC) template beginning on the first day of the first open enrollment period that begins on or after Saturday, April 1, 2017. The new template and accompanying instructions can be accessed here at the Department of Labor's SBC Web page. The new template is shorter than the previous template and includes a new third Coverage Example, but deletes the Questions and Answers about Coverage Examples section.
Other significant changes to the SBC compliance requirements are:
→ Most SBCs must include an issuer website where the individual policy or group certificate of coverage can be reviewed and obtained. This requirement does not apply to self-insured health plans.
→ SBCs may still be distributed by a third party, so there is no need for employers to duplicate distribution of SBCs. However, when a plan sponsor monitors the SBC distribution and notes any non-compliance, the burden falls on the plan sponsor to correct the SBC and even change third-party vendors if required.
→ Abortion coverage information must be included in the SBC. The plan or issuer must disclose in the SBC whether non-excepted abortion services as well as excepted abortion services (abortion services for which public funding is permitted) are covered or excluded under the plan. This requirement applies only to individual policies offered on the marketplace or exchange.
As a review, SBCs must be sent out by:
→ Health insurance issuers (including a group health plan that is not a self-insured plan) offering health insurance coverage within the United States. This includes HRAs and FSAs.
→ Self-insured group health plans, with the SBC to be sent out by the plan sponsor or designated administrator of the plan.
SBCs are not required for:
→ Expatriate health plans.
→ Medicare Advantage plans.
→ Employee Assistance Plans (excepted benefits).
→ Health Savings Accounts (HSAs).
→ Dental and Vision coverage (excepted benefits).
Have questions about the new SBC template? Contact a Plexus client service team member at 847-307-6100 (Deer Park, Ill.), 312-606-4800 (Chicago/Loop), 972-770-5010 (Dallas) or 405-840-3033 (Oklahoma City), or contact us via the Web. We are here to help -- and we are happy to help.