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Implementation FAQ Addresses Timing for Finalizing SBC Changes

From the April 02, 2015 EBIA Weekly

The IRS, DOL, and HHS have jointly issued FAQ guidance setting forth the anticipated timeline for finalizing proposed regulations relating to the summary of benefits and coverage (SBC) and proposed revisions to the SBC template, instructions, uniform glossary, and other materials (see our article). According to the FAQ, the regulations will be finalized in the “near future” and will be effective for plan years beginning on or after January 1, 2016. The FAQ specifies that this includes 2015 open enrollment periods relating to coverage beginning on or after January 1, 2016. While the FAQ reiterates the agencies’ commitment to updating the SBC template and related materials as quickly as possible, it suggests that they may not be available for 2015 open enrollment periods. Rather, revisions to the SBC template and other materials are expected to be finalized by January 2016, and would apply to plan years beginning on or after January 1, 2017. In developing the updated template and other materials, the agencies intend to take into account consumer testing and input from stakeholders, including the National Association of Insurance Commissioners (NAIC).

EBIA Comment: The proposed SBC regulations (issued in December 2014) indicated that the changes would generally apply to plan years beginning on or after September 1, 2015, so this FAQ provides a little more breathing room. Distribution of the SBC is an important disclosure requirement under health care reform. Let’s hope that the timeframe for finalizing in the “near future” is soon enough for plan administrators and insurers to implement the changes in time for the affected open enrollment periods—and that the good faith compliance standard will continue to apply (see our article). For more information, see EBIA’s Health Care Reform manual at Section XVI (“Summary of Benefits and Coverage (SBC)”). See also EBIA’s ERISA Compliance manual at Section XXIV.O (“Summary of Benefits and Coverage (SBC) Under Health Care Reform”) and EBIA’s Group Health Plan Mandates manual at Section XXVIII.C (“SBC Disclosures About Group Health Plan Mandates”).

Contributing Editors: EBIA Staff.

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