Employers gearing up for Open Enrollment and getting their plan materials together should be sure to remember the Summary of Benefits and Coverage required under health care reform.
The Affordable Care Act requires a new plan summary intended to assist employees in comparing health coverage options. The Summary of Benefits and Coverage (SBC) was first required to be distributed in connection with open enrollment periods for the 2013 plan year that began on or after September 23, 2012. This fall will be the second year the SBC will be required to be distributed.
An SBC must be distributed to participants and beneficiaries when they first enroll in coverage, during the open enrollment period, and at other specified times. The Department of Labor (along with Treasury and HHS) issued a template format that must be used for the SBC.
The SBC template was updated in May 2013, with changes applicable to the 2014 plan year. The SBC now must include a statement regarding whether the plan qualifies as minimum essential coverage and if it provides minimum value. If it is easier for a plan to use the old SBC template, the SBC must be accompanied by a cover letter that addresses minimum essential coverage and minimum value.
Employers should be working with their insurers and gathering deciding who will be drafting and distributing the SBC in connection with the upcoming open enrollment period.
