The U.S. Departments of Treasury, Labor, and Health and Human Services (the Departments) recently issued new guidance regarding the intended timeframe for the use of the new summary of benefits and coverage (SBC) template and instructions, an updated uniform glossary and other associated materials.

Background

The Affordable Care Act (ACA) generally requires group health plans and health insurance issuers offering group or individual health insurance coverage to provide an SBC to participants and beneficiaries. The Departments issued revised final regulations governing the SBC requirement on June 16, 2015, and published a proposed new SBC template on February 26, 2016. Comments on the proposed template and associated documents are due by March 28, 2016.

New Guidance

On March 11, 2016, the Departments issued Frequently Asked Questions (FAQs) Part 30 discussing the implementation time for the updated SBC template. The FAQs provide the following information:

  • Health plans and issuers who maintain an annual enrollment period will be required to use the new template and associated documents beginning on the first day of the open enrollment period beginning on or after April 1, 2017, with respect to coverage for the plan year or policy year that begins on or after April 1, 2017.
  • Health plans and issuers who do not use an annual enrollment period will be required to use the new template and associated documents beginning on the first day of the first plan year or policy year that begins on or after April 1, 2017.

The Departments intend to review all comments and finalize the SBC template and related documents in order to implement these deadlines.