The Summary of Benefits and Coverage regulation may seem scary, but it isn’t, really! On October 5, 2012, BCBSM sent the following letter to customers outlining the Health Care Reform requirement to provide a Summary of Benefits and Coverage (SBC) to participants and beneficiaries who enroll or re-enroll through an open enrollment period (including late and re-enrollees).The SBC must be provided beginning on the first day of the first open enrollment period that begins on or after September 23, 2012. Here is a document outlining theร responsibilities, time frames, and triggering events of an SBC.
Now here comes the not so scary part.
The Department of Labor’s (DOL) approach to this regulation is: “
The regulation on the Federal Register reads that a health insurance issuer offering group or individual health coverage that fails to provide the information required, will be subject o a fine of not more than $1,000 per each failure.
BUT WAIT, it’s not that scary.
According to the DOL, Consistent with this guidance, during this first year of applicability, the Departments will not impose penalties on plans and issuers that are working diligently and in good faith to provide the required SBC content in an appearance that is consistent with the final regulations.
PHEW!
For all renewals on the horizon, an SBC will be provided during open enrollment. Furthermore, we are working diligently to ensure that each of our clients has a SBC on file to provide to any employee, current or prospective.
See, the scary part would be if you didn’t have AFG as your benefits broker and consultant!