Dept. of Labor Releases New FAQ

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The Department of Labor (DOL) has released a list of frequently asked questions (FAQ) regarding the summary of benefits and coverage and uniform glossary (SBC) under the Affordable Care Act (ACA). The SBC must be provided by the insurance issuer or the plan sponsor depending on whether the plan is fully-insured or self-funded.

Here is a breakdown of what the FAQ addressed:

  • An updated SBC template and sample form
  • Guidance on what to do if a plan is already in the process of preparing SBCs for issue and is worried about the administrative burden of incorporating the new data elements
  • Whether changes have been made to the SBC template for 2014 to be consistent with the ACA’s requirement to eliminate all annual limits on essential health benefits
  • If additional coverage examples are going to be added to the 2014 SBC
  • Safe harbors related to the requirement to provide an SBC for the first year of applicability; and for insurance products that are no longer being offered for purchase (“closed blocks of business”)
  • Does an SBC related anti-duplication provision for group health coverage apply to student health insurance coverage

If you have not already read it, you may be interested in a previous Keenan briefing on this topic that can be found at: //www.keenan.com/news/brief/2012/BRF_20120309_SBCRequirements_KA.pdf