One of the mandates under the Affordable Care Act is the requirement to provide a Summary of Benefits and Coverage (SBC) to all eligible individuals by the start of your open enrollment period. The Department of Labor (DOL) has updated its SBC template, and your organization must use the new template with all open enrollments beginning on or after April 1, 2017.
Under the revised format, SBCs will be shorter, typically five pages in length. The DOL has tried to simplify the SBC to make some of the information easier to understand. It has also added a new coverage example dealing with a simple fracture. The DOL has posted the new SBC templates, instructions and related materials on its website.
As with the former template, the DOL has strict requirements on both the content and the appearance of the SBC form. In most cases, you must use stock language throughout the SBC, but you may revise the language to the extent necessary to ensure that the SBC accurately describes your medical plan’s benefits. You should have a separate SBC for each medical option available under your plan.
Some employers may wonder if they have to worry about these new templates since Congress is working on legislation that would ostensibly “repeal” or “repeal and replace” the Affordable Care Act. None of the bills currently under consideration, however, would repeal the SBC requirements. Therefore, employers should be sure to use updated SBCs as they gear up for open enrollment.
If you have any questions about preparing or distributing the new SBCs, please contact Norbert Kugele, Stephanie Grant, Kent Sparks or any other member of the Warner Norcross & Judd Employee Benefits Practice Group.
