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Comments sought on changes to summary of benefits and coverage (SBC) and uniform glossary templates
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.
Proposed changes to the regulations regarding the summary of benefits and coverage (SBC) and uniform glossary documents that group health plans must provide annually at open enrollment were published in the
Federal Register on Dec. 30, 2014, by the departments of Health and Human Services, Labor, and the Treasury.
SBCs must be provided for each “benefit package” for which an employee is eligible. Upon renewal, an SBC need only be provided for the specific benefit package in which a participant is enrolled. The SBC must also be provided to participants no later than seven days following a request.
The proposed rule would amend the
final rule published on Feb. 14, 2012, and includes revisions to the current SBC template, instruction guide, uniform glossary and other supporting materials for compliance with the proposed regulations. Samples of current and proposed templates were
posted on the Department of Labor’s website. If finalized, the revisions would take effect for coverage beginning on or after Sept. 1, 2015.
Proposed Templates(effectiveon or after 9/15/2015)
Summary of benefits and coverage
Revised instruction guide
Revised uniform glossary
Source: U.S. Department of Labor.
The proposed changes are “designed to improve access to important plan information so consumers can make informed choices when shopping for and renewing coverage, as well as to provide clarifications that will make it easier for health insurance issuers and group health plans to comply with providing this information,” according to
a fact sheet issued by the federal Centers for Medicare and Medicaid Services (CMS).
Formatting and Content Changes
The Affordable Care Act (ACA) limits the length of the SBC to four pages. The 2012 final rule interpreted this requirement as a limit of four double-sided pages for summarizing plan coverage and costs (excluding explanatory information about the SBC itself, which is also included in the template).
Under the proposed rule, the SBC for a standard group health plan would be shortened to two-and-a-half double-sided pages for summarizing plan coverage and costs. Information not required by the ACA and identified as less useful for consumers choosing coverage would be removed from the template.
The proposed rule would also make a number of changes to the content of the SBC and uniform glossary to reflect the ACA’s private insurance market reforms. For example, references to annual limits for essential health benefits and pre-existing condition exclusions would be removed. In addition, the disclosures relating to continuation of coverage, minimum essential coverage, and minimum value would be revised to provide more useful information to consumers.
For the uniform glossary, the rule proposes to revise some of the existing definitions and to add new definitions reflecting important insurance or medical concepts (such as “claim,” “screening,” “referral” and “specialty drug”), as well as key terms that are relevant in the context of the ACA (such as “individual responsibility requirement,” “minimum value” and “cost-sharing reductions”).
Reducing Unnecessary Duplication
The proposed rule would help prevent unnecessary duplication by requiring only a single SBC per group health plan when the plan sponsor:
In addition, the proposal clarifies that if a plan sponsor is negotiating group coverage terms after an application has been filed and information required to be in the SBC changes, the plan or issuer would not be required to distribute an updated SBC to employees (unless one is requested) until the first day of coverage.
The federal agencies are accepting comments on the proposed rule through March 2, 2015.
Stephen Miller, CEBS, is an online editor/manager for SHRM. Follow him on Twitter
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