On Dec. 22, 2014, the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) released proposed regulations concerning the summary of benefits and coverage (SBC). The proposed regulations would amend the final SBC regulations from February 2012, and would revise the SBC template, instructions guides and uniform glossary. The SBC template would be shortened to two and a half double-sided pages instead of the current four double-sided pages.
If the proposed regulations are finalized, the Departments expect that the new SBC requirements and uniform glossary would apply to plans that begin on or after September 1, 2015.
ACA establishes a penalty of up to $1,000 for each willful failure to provide the SBC. Failing to provide the SBC may also trigger an excise tax of $100 per day per individual for each day of noncompliance.