New Summary of Benefits and Coverage Template Delayed

April 2, 2015
3 min read

March 30, 2015 – In a recent response by the Department of Labor (DOL) in their Affordable Care Act (ACA) FAQ, we learned that the new Summary of Benefits and Coverage (SBC) template and related documents are now being delayed until 2016. However, some changes to the regulation will remain as scheduled for 2015.
So, which regulations are delayed until 2016?
The DOL anticipates that the SBC template, which will go through consumer testing, will be finalized in January 2016, and will apply to 2017 coverage. Its use is expected to begin during fall 2016 open enrollment for plan years beginning on or after January 1, 2017. Expected changes to the template include, but are not limited to:

  • An additional cost example for a foot fracture treated in an ER
  • Updated claims/pricing data for the coverage example calculator
  • New minimum essential coverage (MEC) and minimum value information
  • Issuer website for specific policy or group certificate of coverage information
  • Uniform glossary revisions
  • Removal of annual limits for essential health benefits (EHBs) information

What is still required for 2015?
The following are proposed regulations that are still expected to take effect on September 1, 2015 for plan years beginning on or after January 1, 2016:

  • Applicability to health reimbursement accounts (HRAs) and health savings accounts (HSAs), excepted benefits, expatriate coverage and Medicare Advantage plans
  • Responsible entities and their role in monitoring for compliance when designating to a 3rd party
  • The SBC must be provided at enrollment or re-enrollment

Additional information regarding the ACA SBC is available here.
If you have questions about this delay, please contact us at 1-800-250-2741 or

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