By David Slaughter, JD, Senior Legal Editor
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The dates when group health plans should begin using the most recently revised summary of benefits and coverage (SBC) template were clarified by the Centers for Medicare and Medicaid Services (CMS) in a July 8 Q&A document.
For plans or insurers with an annual open enrollment period, the version of the template and related documents that CMS issued April 6 should be used starting on the first day of any such period that begins April 1, 2017, or later. Those without an annual open enrollment period should start on the first day of the first plan year that begins on or after that date.
Qualified health plans offered through the Affordable Care Act (ACA) exchanges must use the 2018 SBC during the 2018 open enrollment period, which begins November 1, 2017.
Other frequently asked questions included in the guidance addressed how the transition will apply to form review by insurance regulators and how to complete the template’s example for “treatment of a simple fracture.”
The SBC requirement was included in the ACA with the goal of helping plan participants understand and compare their coverage options. Plans and insurers must use a standard template developed by the U.S. Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury. The most recent round of changes includes the new coverage example and an updated glossary of terms.
|  David A. Slaughter, JD, is a Senior Legal Editor for BLR’s Thompson HR products, focusing on benefits compliance. Before coming to BLR, he served as editor of Thompson Information Services’ (TIS) HIPAA guides, along with other writing and editing duties related to TIS’ HR/benefits offerings. Mr. Slaughter received his law degree from the University of Virginia and his B.A. from Dartmouth College. He is an associate member of the Virginia State Bar.
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