Coming soon to a group health plan near you: a summary of benefit coverage – or SBC. Federal agencies have issued proposed rules, including sample SBC documents and instructions, and a new SBC glossary that will need to be included with your four-page SBC. Mark Holloway, JD and co-director of the compliance services division at Lockton just wrote an explanatory alert on the topic, called Feds Propose Rules on New Four-Page Health Plan Summaries and Advance Notice Requirement for Plan Changes.
Oh! By the way, Holloway points out, four-pages means four, double-sided pages. Plans would have to provide the SBC as a stand-alone document, free of charge. And for plans with multiple coverage options (e.g. PPO, HMO, consumer-driven option, etc.) – you guessed it! A separate SBC would be required for each option.
The new rules are written for insured programs, and present some difficult issues for employer plans, especially self-funded and consumer-driven plans. That the rules require group health plans to distribute SBCs at different times and within seven days of a request creates its own potential hardship for employers.
You will want to read this alert from the Lockton Health Reform Advisory Practice to learn more about the ins and outs of the proposed rules and timeframe.