The Department of Labor, the Internal Revenue Service and the U.S. Department of Health and Human Services have released final versions of the Summary of Benefits and Coverage (SBC) template and Uniform Glossary documents required under the Affordable Care Act.
The IRS also has released updates to Forms 1094-C and 1095-C. The updated SBC template and IRS forms all will need to be used in 2017.
Plans will be required to use the new final SBC forms during the first open enrollment period on or after April 1, 2017 — or, if the plan does not use open enrollment, the first day of the plan year that begins on or after this date.
The IRS changes to Forms 1094-C and 1095-C are in draft form. A finalized version will be available before applicable large employers are required to provide the Form 1095-C to each employee on Jan. 31, 2017. So far, the IRS has proposed only minor changes to the forms, including removing the transitional relief that was available on Line 22B of Form 1094-C and simplifying and clarifying the instructions to Form 1095-C.
Employers will need to ensure that they, their insurers or their third-party administrators use the updated SBC template and IRS forms in 2017. The updated SBC template is available at the CMS website, and the IRS’s website contains the draft forms here and here.