Health plans and issuers that have an annual open enrollment period beginning on or after April 1, 2017 for plan years beginning on or after April 1, 2017 must use the new 2017 templates and instructions for the Summary of Benefits and Coverage (SBC). Plans that do not offer an annual open enrollment period must begin using the new SBC for plan years beginning on or after April 1, 2017.
Note: For calendar year plans, the new SBC template must be used for the annual open enrollment in 2017 for calendar years beginning January 1, 2018.
Completing and distributing the SBC is required under PHS Act section 2715. This requirement has not been suspended or otherwise repealed. The SBC template and instructions include stringent requirements and allow only specific modifications to reflect the coverage being offered. Care should be taken when preparing an SBC to ensure it complies with the format and content requirements.
Note: SBCs for HRAs are particularly challenging due to the restrictive drafting requirements for the SBC. We previously prepared partially completed SBC templates for HRAs. We have now updated those documents to comply with the April 2017 templates and requirements.
Please contact us if you are in need of assistance in reviewing or drafting an SBC, using the new template and instructions, or if you are in need of the updated SBC templates for HRAs.