Reporting and Disclosure

The Affordable Care Act (ACA) includes several new reporting and disclosure requirements. Notices are required to disclose dependent coverage, patient protections, the elimination of lifetime benefit limits and the grandfathered status of the plan. Additional disclosures are required about automatic enrollment, the availability of the health care exchanges and claims appeals and reviews. By March 23, 2012, plan sponsors must also provide a uniform summary of coverage to participants.


Government Resources
Analysis 

Government Resources

The DOL, HHS and IRS have released another set of Frequently Asked Questions (FAQs) about the summary of benefits and coverage (SBC). The final FAQ (number 14) addresses an error that has been corrected. In the diabetes treatment scenario, the version originally posted contained a typographical error, listing the allowed amount for insulin as $11.92, rather than $119.20 – a difference that impacts the total cost of care for diabetes in the coverage example calculations.To correct this error, the Departments have posted updated versions of the SBC template, the sample completed SBC, and the guide for coverage examples calculations – diabetes scenario (see below). 5/11/12 (New)

The Departments of Labor, Health and Human Services (HHS), and the Treasury released Affordable Care Act Implementation FAQs - Set VIII. These questions and answers address implementation of the summary of benefits and coverage (SBC) provisions of the Affordable Care Act. 3/19/12  

2012 Culturally and Linguistically Appropriate Services (CLAS) County Data, 3/9/12   

The Departments of Labor, Treasury and Health and Human Services have released final regulations under the Affordable Care Act (ACA) that require health insurers and group health plans to provide concise and comprehensible information about health plan benefits and coverage to those with private health coverage. The goal is to make it easier for individuals and employers to directly compare one plan to another. 2/14/12  

The EBSA released an FAQ addressing the timing of the final Summary of Benefits and Coverage (SBC) regulations. Until final regulations are issued and applicable, plan sponsors are not required to comply with the SBC requirements. It is anticipated that the final regulations, once issued, will include an applicability date that gives group health plans and health insurance issuers sufficient time to comply. Therefore this FAQ implies that the compliance date  for the SBC requirements will be later than the original date (March 23, 2012) specified. 11/17/11  

Government agencies have proposed rules requiring health insurers and group health plans to provide consumers with clear, consistent and comparable information about their health plan benefits and coverage. The proposed regulations would ensure consumers have access to two forms that will help them understand and evaluate their health insurance choices, including an easy to understand Summary of Benefits and Coverage and a uniform glossary of terms commonly used in health insurance coverage.  


The National Association of Insurance Commissioners Consumer Information Subgroup is working with the Secretary of Health and Human Services (HHS) to develop standards for a summary of benefits and coverage explanation. The samples and explanatory information are posted on their website. 4/21/11  

Analysis