EMPLOYERS MUST DISTRIBUTE GROUP HEALTH PLAN SUMMARY OF BENEFITS AND COVERAGE DURING THIS FALL’S OPEN ENROLLMENT
The Affordable Care Act requires group health plans to distribute a Summary of Benefits and Coverage ("SBC") to individuals who are eligible for coverage. The purpose of the SBC is to help eligible persons understand their plan coverage and compare it to other coverage available to them.
Insurance companies are required to provide the SBC for insured plans. Employers are required to provide the SBC for self-insured plans. Employers may contract with their third party administrators (TPAs) to prepare and distribute the SBC.
The first SBC must be distributed by the first day of the open enrollment period that begins on or after September 23, 2012.
We encourage employers with a self-insured group health plan to contact their TPA now to confirm whether the TPA will provide the SBC. If the TPA will not prepare the SBC, employers must make other arrangements. Please contact us if you would like us to review the SBC prepared by your TPA or draft the SBC if your TPA will not prepare it.
Links to Regulations and Templates
IRS, DOL and HHS SBC Final Regulations were published on February 14, 2012
The agencies issued SBC FAQs on March 19, 2012: FAQs About Affordable Care Act Implementation Part VIII
The agencies issued a second set of SBC FAQs on May 11, 2012: FAQs About Affordable Care Act Implementation Part IX
There are SBC templates, instructions and a uniform glossary at the DOL/EBSA website:
Patient Protection and Affordable Care Act/ Summary of Benefits and Coverage Rules and Guidance
If you have any questions about applying these dollar limits to your plans, please contact a member of Oppenheimer's Employee Benefits Group.