Special Guest Blog by David O’Shea of Significa Benefit Services
Summary of Benefits and Coverage
The Affordable Care Act (ACA), often referred to as “Health Care Reform”, requires health plans to automatically distribute a standardized Summary Of Benefits and Coverage (SBC) and uniform glossary. The SBC must accurately describe the benefits and coverage under the plan. The uniform glossary must contain the terms commonly used in health insurance coverage. These new disclosure requirements apply to both grandfathered and non-grandfathered health plans. The SBC and glossary are to go into use starting the first plan year after September 23, 2012.
On August 22, 2011, the Department of Labor, Health & Human Services and the Treasury published regulations implementing the new disclosure requirements. The regulations propose standards for group health plans that govern who must provide an SBC, who must receive the SBC, when the SBC must be provided and how the SBC must be provided. To develop such standards, the ACA requires the Departments to consult the National Association of Insurance Commissioners (NAIC).
In conjunction with the proposed regulations, the Department published a separate document that provides the required template for the SBC which includes the proposed instructions and sample language for completing the template, as well as the required uniform glossary. All of the guidance involving the SBC and uniformed glossary is available under “Affordable Care Act Regulations and Guidance”/”Summary of Benefits and Coverage and Uniform Glossary” at http://www.dol.gov/ebsa/healthreform.