The Affordable Care Act’s Summary of Benefits and Coverage and Uniform Glossary 2715, that mandates distribution of benefit summaries to employees, has been postponed. The decision to postpone the March 12, 2012 deadline was made by three agencies, the Department of Health and Human Services (HHS), Labor, and Treasury, until a date is determined in the final rule. A set of FAQs was posted on the Department of Labor website and is available here.
Some main characteristics of 2715 of the healthcare law are as follows:
- Group health plans and health insurance issuers must provide a Summary of Benefits and Coverage and Uniform Glossary (SBC) that satisfies specific standards.
- Health plans must provide enrolled employees with a simplistic and more inclusive summary of the plan benefits and coverage.
- Employees must be provided with a “plain-English” glossary of commonly used terms in SBC’s, for example, “co-pay” and “deductible”.
- The SBC can be no longer than four double-sided pages.
- Both grandfathered and non-grandfathered plans are required to be compliant in providing SBCs.
- A SBC must be delivered to employees at least 30 days prior to reissuance or renewal of coverage and should accompany written open enrollment materials that are distributed to employees.
- At least 60 days notice must be provided by plans and issuers before any significant modification to the health care plan or coverage can become effective during the plan year. (Plan changes to become effective on the renewal date should be noted in the new SBC distributed 30 days before renewal date.)
- An SBC must be provided to an employee within seven days of a request for one.
Again, the effective date for the Summary of Benefits Mandate has been postponed without direction from federal agencies as to when a final rule can be expected. We will continue to keep you updated as additional information becomes available.
