August 20, 2015
Proposed Changes to SBC Materials Expected to Apply in 2017
Group health plans that enter into a binding contract with another party, such as the issuer, to provide a summary of benefits and coverage (SBC) will need to comply with additional obligations with respect to coverage that begins on or after September 1, 2015.
Specifically, to satisfy the requirement to provide the SBC, final rules require that such a plan must:
- Monitor performance under the contract;
- Correct noncompliance as soon as practicable, if the plan has knowledge that the SBC is not being provided in a manner that complies with the law and has all information necessary to correct the noncompliance; and
- Communicate with affected participants and beneficiaries and begin taking significant steps as soon as practicable to avoid future violations, if the plan has knowledge that the SBC is not being provided in a manner that complies with the law and does not have all information necessary to correct the noncompliance.
As a reminder, a new SBC template and associated documents are generally expected to be finalized by January 2016 and will apply to SBCs for coverage beginning on or after January 1, 2017. Until then, the previously authorized templates may be used without penalty (including the original template), provided the SBC is furnished with a cover letter or similar disclosure that includes additional language indicating whether the plan provides "minimum essential coverage" and "minimum value."
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