Health Care Reform Update: SBC Mandate Update and Obama Admin Compromises on Contraceptives
1. Summary of Benefits and Coverage (SBC) Rules Finalized
- On February 9, 2012, the Departments of Health and Human Services (HHS) and Treasury and Labor issued final rules on the Summary of Benefits & Coverage (SBC), as required by the Affordable Care Act (ACA).
- The Regulations should appear in the Federal Register on February 14, 2012.
- Effective for plan open enrollment periods that start on or after September 23, 2012.
Here are some highlights from the final guidance:
- Health FSAs and HSAs are exempt. Health Reimbursement Arrangements (HRAs), on the other hand, must comply. A stand-alone HRA will need a separate SBC. An HRA integrated with a major medical plan will need to reflect the impact that the HRA has on medical plan deductibles, copayments and other benefits.
- An SBC cannot be replaced by a Summary Plan Description (SPD), even if the SPD provides all of the required information. The SBC template must remain intact and prominently displayed at the beginning of any other benefits materials with which it is combined. A suggestion was to put the SBC immediately after an SPD’s table of contents.
- The SBC template and the corresponding Uniform Glossary of Coverage and Medical Terms look very similar to the earlier proposed forms.
- The agencies have provided a website with tools and a sample completed SBC to assist plans with completion of the SBC.
2. Obama Admin Compromises on Contraceptives
After fierce opposition from Catholic leaders on the new rule requiring that insurance plans offer free contraception, the Obama administration is revising regulations so that religious-affiliated groups do not have to pay for the coverage.
As a recap:
- In January, the administration announced that all insurance plans would be required to cover contraception as part of preventive services mandated by the 2010 federal health law. It exempted houses of worship, like churches, from this mandate, but religious-affiliated institutions, such as universities and hospitals, would have to provide coverage for contraception.
What’s new:
- This month, a compromise was formed after explicit opposition from many religious institutions. The compromise detailed by the president instructs that insurers would work directly with the individuals seeking contraceptive services which would be provided at no cost per the federal health law.
Read more here.
