The U.S. Departments of Labor, Treasury and Health and Human Services (often referred to as the “Departments”) recently released proposed regulations that aim to streamline and simplify the Summaries of Benefits and Coverage (“SBC”) required under the Affordable Care Act (“ACA”). Evidently, the Departments listened to consumers and are proposing changes in response.
The Departments stated with the proposed regulations that consumer research on existing SBC templates, as well as uniform glossaries of key health care terms, showed that consumers did find value in them. They acknowledged that some of the information in the existing document templates is not required by the ACA or needs to be updated.
Some highlights from the proposed changes include:
· A new medical coverage example based on a more typical scenario – foot fracture with emergency room visit – than the existing coverage examples
· Updated pricing assumptions in coverage examples to better reflect true marketplace costs
· Removal of information not required by ACA
· Removal of references to annual limits for essential health benefits and preexisting condition exclusions
· Revised uniform glossary definitions and new definitions reflecting important terms like “individual responsibility requirement,” “minimum value,” and “cost-sharing reductions”
Work Cut Almost in Half
These and other changes result in a less burdensome sample completed template for a standard group health plan that has been shortened to two and one-half double-sided pages rather than four.
Sample the Documents
The following new sample documents will apply to plan years starting on or after September 23, 2015, and are available for review at http://cciio.cms.gov and www.dol.gov/ebsa/healthreform, (though employers should not use these documents until they are finalized later this year):
· SBC template. Available in PDF and MS Word formats.
· Sample completed SBC. Completed using information for sample health coverage; provides a general illustration of a completed SBC for coverage under a group health plan.
· Instructions. Separate instructions group and individual coverage examples.
· “Why This Matters” language. Language preparers must use when completing the “Why This Matters” column on the first page of the SBC template. Two language options are provided depending on whether the answer in the applicable row is “yes” or “no”, according to the terms of the plan or coverage.
· Uniform glossary. The uniform glossary of health coverage and medical terms may not be modified by plans or issuers.
Public comments will be collected until March 2, 2015 and final regulations and template forms should be out by summer.