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Reporting and Disclosure
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
- Additional Guidance on the Summary of Benefits and Coverage, Proskauer Rose, 5/18/12 (New)
- IRS Asks for Comments on Employer Reporting of Health Insurance Coverage Under Affordable Care Act, Mintz Levin, 5/8/12 (New)
- Health Plan Quality Improvement Strategy Reporting Under the Affordable Care Act: Implementation Considerations, Commonwealth Fund, 4/6/12
- Departments Issue FAQs Simplifying Summary of Benefits and Coverage Requirement, Buck Consultants, 3/27/12
- HHS, DOL, and Treasury Issue FAQs Under the Affordable Care Act’s “Summary of Benefits and Coverage” Requirement, Mintz Levin, 3/27/12
- Agencies Release FAQs on Compliance With Summary of Benefits and Coverage Provisions, Aon Hewitt, 3/26/12
- Summary of Benefits FAQs Do Not Answer Issue of Effective Date, Practitioners Say, Pension & Benefits Daily via Morgan Lewis, 3/23/12
- Do You Need to Provide the New 4-Page Summary Under Health Care Reform in a Foreign Language?, McKenna Long & Aldridge, 3/21/12
- Agencies Issue Eighth Set of FAQs on Affordable Care Act Implementation, Littler, 3/21/12
- Final Rule Issued on Summary of Benefits and Coverage Required by the Affordable Care Act, Segal, 3/20/12
- Summaries of Benefits and Coverage Due This Fall, Morgan Lewis, 3/13/12
- Summary of Benefits and Coverage: Final Rules Issued, Requirement Effective Beginning September 23, 2012, Mintz Levin, 3/2/12
- Final Guidance Issued on Summary of Benefits and Coverage, Buck Consultants, 3/1/12
- The SBC Countdown Has Begun: Group Health Plan Summary of Benefits and Coverage Final Rules Issued, Drinker Biddle, 2/29/12
- Health Care Reform Summary, Quarles & Brady, 2/22/12
- Agencies Issue Final Rule Regarding Summary of Benefits and Coverage, Littler, 2/16/12
- Summary of Benefits and Coverage Final Regulations May Impact You as Early as Open Enrollment 2012, Groom Law, 2/15/12
- Agencies Release Final Regulations Regarding Summary of Benefits and Coverage and Uniform Glossary Requirements, Aon Hewitt, 2/13/12
- Less than Half of Employers Are Ready to Distribute Health Care Reform Summary of Benefits and Coverage Materials, HighRoads, 2/7/12
- U.S. Department of Labor FAQ #7 Delays Summary of Benefits and Coverage Requirement under ACA; Clarifies Rules under MHPAEA, Proskauer Rose, 12/7/11
- Health Plans Get Reprieve from Immediate Need to Develop and Provide Uniform Summary of Benefits and Coverage, Segal, 11/21/11
- Agencies Delay Summary of Benefits and Coverage Requirements, Issue FAQs on Mental Health Parity, Sutherland, 11/21/11
- Summary of Benefits and Coverage and Uniform Glossary Proposed Rule: Implementation and Annual Ongoing Costs of Compliance, America's Health Insurance Plans (AHIP), 10/21/11
- Departments Issue Summary of Benefits and Coverage Proposed Regulations, Buck Consultants, 10/19/11
- Uniform Coverage Summaries for Consumers, Kaiser Family Foundation, 10/11/11
- Agencies Issue Guidance on Summary of Benefits & Coverage, McGuire Woods, 9/26/11
- Comments Requested on Draft Template for the Uniform Summary of Health Benefits, Segal, 8/31/11
- New Summary of Benefits and Coverage Required for Health Plans in 2012, Morgan Lewis, 8/26/11
- Agencies Propose Rules for Uniform Statements of Benefits Under PPACA, PricewaterhouseCoopers, 8/25/11
- Health Care Reform: Guidance Released on Uniform Summary of Benefits and Coverage, Proskauer Rose, 8/23/11
- New Rules for Summaries of Health Benefits and Coverage, Sutherland, 8/23/11
- Agencies Issue Summary of Benefits Proposed Regulation Under PPACA, Groom Law Group, 8/22/11
- Agencies Release Proposed Regulations and Request for Comments Regarding Summary of Benefits and Coverage and Uniform Glossary Requirements, Aon Hewitt, 8/22/11
- Short, Fast and to the Point – Proposed PPACA Benefit Summary Rules Set Tight Standards, Ogletree Deakins, 8/18/11
- Repeal of the Affordable Care Act's 1099 Reporting Requirement and Changes in the Subsidies Available to Individuals in 2014, Segal, 4/18/2011
- Notice of Coverage Options, Deloitte, 2/15/11
- New Health Plan Notices Required Under Health Care Reform, Mintz Levin, 11/15/10
- Required Participant Notices Under Health Care Reform, Miller Johnson, 10/21/10
- Dealing with Health Plan Disclosures, Warner Norcross & Judd, 10/13/10
- New Notices and Disclosures Due Under Health Care Reform, Mercer, 9/8/10
- Health Care Reform: New Reporting and Disclosure Rules, Jenkins Insurance Group, 8/20/10
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