On April 6, 2016, the US Department of Labor posted final versions of the updated summary of benefits and coverage (SBC) template and instructions, updated uniform glossary and other associated materials. In previous guidance, the US Departments of Treasury, Labor, and Health and Human Services provided that health plans and issuers who maintain an open enrollment period will be required to start using the new template and associated documents 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 open enrollment period should begin using these documents on the first day of the first plan year or policy year that begins on or after April 1, 2017.
Employers should begin preparations to ensure that the finalized documents are ready for distribution by the required implementation date. Health plans and issuers with calendar year plans and open enrollment periods must be ready to use the new documents during the 2017 open enrollment period for coverage that begins on January 1, 2018. Health plans and issuers with calendar year plans and no open enrollment period should be prepared to use the documents by January 1, 2018.