On February 26, the Department of Labor (DOL) issued a formal notice along with the proposed new Summary of Benefits and Coverage (SBC) template, instructions and related documents for final comment and review. Comments are due by March 28, 2016.

The Affordable Care Act requires SBCs as a means to provide individuals with standard information so they can better understand and compare medical plan offerings. Final regulations implementing SBC requirements were issued in June 2015, but release of final documents and forms was delayed to a later date.

In this latest development, the DOL has released revised versions of the SBC template and other materials, based on input from the National Association of Insurance Commissioners (NAIC) and other stakeholders.

The general format of the SBC template is similar to the current version. Proposed changes to the template include:

• Streamlined content, e.g., removal of Q&A about coverage examples, which reduced the template to 5 pages (SBC limit remains 8 pages/4 double-sided pages)
• An additional cost example for a foot fracture treated in an emergency room
• Updated claims/pricing data for the coverage example calculator
• New minimum essential coverage and minimum value language, as well as new continuation and appeals/grievance rights language
• Revised language for some sections of the template
• An updated Uniform Glossary

While the effective date for using the new template has not been announced, the DOL indicated in a phone call that the new SBC template will take effect for plan years beginning on or after April 1, 2017. In this scenario, calendar year plans with 1/1 effective or renewal dates would not need to use the new template until the fall 2017 enrollment period for 2018 coverage.

No Impact on Expatriate Plans

Both U.S. issued fully insured and self-funded expatriate plans are exempt from the SBC requirements. This new template does not impact expatriate plans.

Reference Materials

Links to the Notice, as well as the current and proposed SBC template, instructions and related materials are available at http://www.dol.gov/ebsa/healthreform/regulations/summaryofbenefits.html.

More complete information regarding timing and specific impacts to existing SBCs and processes will be provided after the final comment period and once final regulations are issued.