New to HR? Templates, tools and development to make you a seasoned pro in no time.
Shawn Premer shows how doing the right thing for employees leads to positive business results.
Is your employee handbook keeping up with the changing world of work? With SHRM's Employee Handbook Builder get peace of mind that your handbook is up-to-date.
Build competencies, establish credibility and advance your career—while earning PDCs—at SHRM Seminars in 12 cities across the U.S. this spring.
#SHRM18 will expand your perspective – on your organization, on your career, and on the way you approach HR. Join us in Chicago June 17-20, 2018
Members may download one copy of our sample forms and templates for your personal use within your organization. Please note that all such forms and policies should be reviewed by your legal counsel for compliance with applicable law, and should be modified to suit your organization’s culture, industry, and practices. Neither members nor non-members may reproduce such samples in any other way (e.g., to republish in a book or use for a commercial purpose) without SHRM’s permission. To request permission for specific items, click on the “reuse permissions” button on the page where you find the item.
Employers conducting their annual group health plan open enrollments this fall must remember to include a summary of benefits and coverage (SBC), along with a uniform glossary to that SBC, as required by the Patient Protection and Affordable Care Act. The SBC is required for both grandfathered and nongrandfathered plans in the insured and self-funded market, as well as the individual market.
Recent guidance from the U.S. Department of Labor, the U.S. Department of Health and Human Services, and the U.S. Treasury updates the SBC templates that describe coverage beginning on or after Jan. 1, 2014, and before Jan. 1, 2015. The
updated templates and a
sample completed template include a statement as to whether the group health plan provides minimum essential coverage and whether that coverage meets the minimum value requirements (i.e., the plan must cover at least 60 percent of the total allowed cost of benefits that are expected to be incurred under the plan).
The updated templates are not required for SBCs issued for the 2014 plan year; however, if the group health plan does not use the updated templates for the upcoming open enrollment, the new guidance requires the plan or insurance company to include a disclosure with the SBC. That disclosure may be in the form of a cover letter stating whether the plan provides minimum essential coverage and meets the minimum value requirements. The guidance includes sample language for that disclosure, which can be found at question two (Q2) on the DOL’s
“FAQs about the Affordable Care Act Implementation Part XIV.”
The other clarification to the SBC for the 2014 plan year is that additional coverage examples are not required as part of the SBC at this time. Plans and insurance companies should continue to answer questions on the SBC template regarding annual limits even though plans are prohibited from imposing annual limits on essential health benefits effective for plan or policy years beginning on or after January 1, 2014. The SBC should include detailed information on any limits on specific covered benefits that are not essential health benefits.
Remember that a group health plan must provide advance notice of a material modification if there is a material modification to the plan that is not reflected in the most recently provided SBC. Only material modifications affecting the SBC content would require this advance notice. For material modifications not reflected in the most recent SBC, notice is required (in paper or electronic form) no later than 60 days prior to the date that the change will become effective. Employers will want to keep this advance notice requirement in mind for plan terminations or other significant benefit changes.
Stephanie A. Smithey is a shareholder in the Indianapolis office of
Ogletree Deakins, which provides counsel to management in every area of labor and employment law.
Republished with permission. © 2013 Ogletree Deakins. All rights reserved. This article should not be construed as legal advice.
Related External Resource:
Timeline of Provisions: Summary of Benefits and Coverage and the Uniform Glossary, UnitedHealthcare
Related SHRM Articles:
SHRM Online Health Care Reform Resource Page
Keep up with the latest news. Sign up for SHRM’s free
Compensation & Benefits e-newsletter
You have successfully saved this page as a bookmark.
Please confirm that you want to proceed with deleting bookmark.
You have successfully removed bookmark.
Please log in as a SHRM member before saving bookmarks.
Please sign in as a SHRM member before saving bookmarks.
Please purchase a SHRM membership before saving bookmarks.
An error has occurred
Recommended for you
Talent Attraction Study: What Matters to the Modern Candidate
Apply by March 23
SHRM’s HR Vendor Directory contains over 3,200 companies