Reminder for SBCs – Yes, Please!

The Affordable Care Act’s requirement that group health plans provide summaries of benefits and coverage (“SBCs”) to applicants and enrollees at various times is not new.  Nevertheless, because of the steep penalties for noncompliance (i.e., $1,000 per failure with respect to each participant or beneficiary and an excise tax of $100 per day with respect to each individual to whom such failure relates) we think it’s worthy of another blog post.  See our July 19, 2012 Newsletter Summary of Benefits and Coverage for Group Health Plans and follow-up August 11, 2016 blog post Departments Finally Publish Updated SBC Template and Instructions for additional background information. Read More ›

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Open Enrollment Looms and ACA Changes are Uncertain – What are Employers to Do?

On the morning of July 28, 2017, another effort to repeal or replace the Affordable Care Act (“ACA”) failed in a 49-51 Senate vote when three Republican senators voted against the bill. Attempts to pass even a trimmed down “skinny” version of the bill were unsuccessful.  Following this dramatic vote, the path forward for health care reform is as uncertain as ever.

With fall open enrollment fast approaching, employers may be wondering what actions to take with respect to their health plans. Given the uncertainty of whether changes will be made to the ACA before open enrollment, employers may wish to proceed as though the ACA will remain in effect for 2018. Read More ›

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Departments Finally Publish Updated SBC Template and Instructions

On April 6, 2016, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued an updated Summary of Benefits and Coverage (“SBC”) template.  The latest template represents an effort by the Departments to enhance consumer access to information regarding their health care options.

Although the new template is shorter than the prior version, it includes more detailed information about cost-sharing, deductibles and out-of-pocket limits.  Moreover, the template adds a new example describing coverage for an in-network emergency room visit.  The Departments intend that these additions will provide consumers with more meaningful information as they select their medical coverage.           Read More ›

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Proposed Regulations for Summary of Benefits and Coverage Seek to Simplify Compliance

As part of Health Care Reform, employers and insurers are required to provide group health plan participants with a Summary of Benefits and Coverage (“SBC”) describing the important features of the group health plan option(s) offered by the employer/insurer.  The SBC is also intended to provide participants a way to easily compare different group health plan options.  The current rules for complying with the SBC requirement were viewed by some as not being “user-friendly.”  On December 22, 2014, the DOL, HHS and Treasury released proposed guidance that is designed “to improve consumer access to important plan information so that [the consumers] can make more informed choices.”

The proposed regulations suggest the following changes/additions:

•  A new coverage example regarding a foot fracture and emergency room visit would be added to the existing coverage examples of “having a baby” and “managing type 2 diabetes.”  These coverage examples have been shown to be helpful in a participant’s understanding of how their coverage works. Read More ›

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