You may recall that, under PPACA, plans were to start providing uniform “summaries of coverage” and uniform definitions by March 23, 2012. This compliance date was delayed pending publication of final rules. Well now they are here. The final rule and guidance documents are now available. Under the final rule, plans with plan years that start September 23, 2012 or later will have to supply SBCs in their next open enrollment.
Rather than try to summarize each document, I suggest you look at them first. As more opinions and guidance are release, I will be providing additional commentary for each. But for now please check out the following official publications to help start your compliance process:
- Final Regulations,
- Compliance Guide,
- Summary of Benefits and Coverage Template
- Sample Completed SBC
- Instructions for Completing the SBC – Group Health Plan Coverage
- Instructions for Completing the SBC – Individual Health Insurance Coverage
- Why This Matters language for “Yes” Answers
- Why This Matters language for “No” Answers
- Uniform Glossary of Coverage and Medical Terms
And as a sort of a catch all page, use this HHS Site for Simulating Coverage which has all the resources.
As we get closer to September 23, there will likely be some modifications. But plan sponsors should start preparing now for compliance for their 2012-2013 open enrollments.
By Keith R. McMurdy
