Under the Affordable Care Act (ACA), the Summary of Benefits and Coverage (SBC) and Uniform Glossary was created to help consumers compare coverage options available to them. This disclosure requirement applies to both grandfathered and non-grandfathered plans. Group health plans and health insurance carriers are required to provide the SBC and uniform glossary free of charge annually.
On December 22, 2014, the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) released proposed regulations on the SBC requirement. The proposed regulations were to revise the SBC template, instruction guides and uniform glossary, and they expected the changes would apply to coverage that begins on or after September 1, 2015. However, that date has been postponed.
On March 31, 2015, the Departments issued a Frequently Asked Question (FAQ) announcing their intention to issue final regulations on the SBC requirement in the near future. The FAQ notes that the final rules are expected to apply in connection with:
- Coverage that would renew or begin on the first day of the first plan year that begins on or after January 1, 2016; or
- Open enrollment periods that occur in the fall of 2015 for coverage beginning on or after January 1, 2016.
Additionally, the new template, instructions and uniform glossary are not expected to be finalized until January 2016, in order to allow for consumer testing and offer an opportunity for the public to provide further input before finalizing revisions to the SBC template and associated documents. The revised template and associated documents will apply to:
- Coverage that would renew or begin on the first day of the first plan year that begins on or after January 1, 2017; or
- Open enrollment periods that occur in the fall of 2016 for coverage beginning on or after January 1, 2017.