New SBC Template Generally Expected to Apply to Plan Years Beginning On or After April 2017

Q&As Address Implementation Date of New SBC Template

The Centers for Medicare & Medicaid Services (CMS) have released new Q&As regarding the applicable date for using the new Summary of Benefits and Coverage (SBC) template and associated documents.

Background
Under the Affordable Care Act (ACA), group health plans and health insurance issuers are generally required to provide a written SBC to plan participants and beneficiaries at specified times during the enrollment process and upon request. On April 6, 2016, federal agencies finalized new versions of the SBC template, instructions, uniform glossary, and related documents.

Applicability Dates for New SBC Template
According to the Q&As, the applicable dates for using the new SBC template and associated documents will be as follows:

• Health plans and issuers that maintain an annual open enrollment period will be required to use the new editions beginning on the first day of any open enrollment period that begins on or after April 1, 2017.
• Health plans and issuers that do not use an annual open enrollment period will be required to use the new editions beginning on the first day of the first plan year that begins on or after April 1, 2017.

Additional information is available in the text of the Q&As. Visit the U.S. Department of Labor's webpage on the SBC and Uniform Glossary for news updates and access to templates and related documents.

Be sure to visit our Summary of Benefits and Coverage (SBC) section for additional information.