The U.S. Department of Labor (DOL) has issued an updated template Summary of Benefits and Coverage (SBC), Glossary of Coverage and Medical Terms, and related materials. The revised materials remain in proposed form, but have been sent to the U.S. Office of Management and Budget with a request that the templates and glossary be approved for three years. It is expected that these revised documents will replace the model SBC template and glossary that the DOL previously issued in December 2014. 

According to an earlier set of DOL Frequently Asked Questions, these revised documents will apply to coverage that renews or begins on or after January 1, 2017. However, the DOL has informally indicated that the effective date will be delayed to apply to plan/policy years beginning on and after April 1, 2017 (and the annual enrollment periods leading up to them. We expect further guidance to that effect. 

The SBC is a precisely formatted document that group health plans and health insurers are required to provide in connection with enrollment and re-enrollment periods. In addition to technical changes, the revisions require the SBC to describe services covered by the plan prior to meeting a deductible and to add a third example on the costs associated with the simple fracture of a bone.

As the federal health care reform effort gained steam, Ballard Spahr attorneys established the Health Care Reform Initiative to monitor and analyze legislative developments. With federal health care reform now reality, our attorneys are assisting health care entities and employers in understanding the relevant changes and planning for the future. They also have launched the Health Care Reform Dashboard, an online resource center for news and analysis on developments under the Affordable Care Act.

Copyright © 2016 by Ballard Spahr LLP.
www.ballardspahr.com
(No claim to original U.S. government material.)

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.