The IAA One Minute Blog

On Monday, March 19, 2012, the Departments of Health and Human Services, Labor, and Treasury, issued a set of frequently asked questions(FAQs) about the implementation of the summary of benefits and coverage (SBC) provision of the Affordable Care Act (ACA). Insurance Administrator of America is here to highlight the important aspects of the FAQs to help you understand and navigate the benefits.

Timeline for SBC Provisions

One of the big questions about the SBC was the timeline for implementation.

For group health plan coverage, plans and issuers must begin to provide the SBC to participants and beneficiaries who enroll or re-enroll during an open enrollment period. The SBC must be provided on the first day of the first open enrollment period that begins on or after September 23, 2012. If they enroll at any other time, the SBC must be provided beginning on the first day of the first plan year that begins on or after September 23, 2012.

The SBC then needs to be sent within seven business days, though it does not need to be received within seven business days.

The SBC's First Year

Many people want to know what the Departments' basic approach for instituting the SBC requirement will look like the first year. The Departments' approach can be narrowed down to:

• Working together with employers, issuers, states, providers, and other stake holders to help them come into compliance with the new law
• Assisting with transition provisions, grace periods, and safe harbor policies to ensure they take effect smoothly

Plans and issuers may be reassured by the fact that the Departments will not impose penalties on plans and issuers during the first year that they are working diligently to provide the required SBC content.

Combining Information

While plans and issuers may be concerned about having to provide a SBC for every part of a participant's benefit package, there is no need to worry. It is possible to combine information so long as it is understandable. Situations in which information can be combined are:

• Coverage tiers within a benefit package
• Different cost sharing selections (i.e. different levels of deductibles, co-payments, and co-insurance)
• Add-ons that could affect cost sharing and other information in the SBC (ex. Health FSA, HRA, HSA, or Wellness programs)

What IAA has to Say

There is a lot of information out there and it can be confusing sometimes. IAA is here to give you the most pertinent and helpful information. Just remember, IAA is always here, ready to work for you.

If you like this article about the ACA click here and here to learn more.