HHS and DOL Issue New Guidance on PPACA’s Summary of Benefits Requirements

HHS, together with the Department of Labor (DOL) released an FAQ regarding the Summary of Benefits Coverage (SBC) requirement imposed by the Patient Protection and Affordable Care Act (PPACA).  This guidance builds on a Final Rule issued by the Departments on February 9, 2012, requiring health insurance issuers and group health plans to provide consumers with an easy-to-understand SBC, as well as a uniform glossary of commonly used health insurance terms beginning September 23, 2012.  Among other things, the new guidance:

  • creates a new safe harbor allowing issuers and health plans to deliver SBCs electronically under certain circumstances;
  • provides further detail about when an SBC must be provided;
  • clarifies certain details about the required format of an SBC; 
  • states that the Departments will not impose penalties on plans and issuers that are “working diligently and in good faith” to comply with the SBC rules during the first year; and
  • provides links to updated versions of the SBC template, sample completed SBC, and the guide for coverage examples calculations, which have been revised to correct a typographical error.

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