Health Care Plan Summary of Benefits and Coverage Distribution Deadline Quickly Approaching for Employers

Employers who maintain health plans may recall from our prior blogs (see “Health Care Plan Annual Enrollment Triage: The Summary of Benefits and Coverage Standards Have Not Been Issued Yet and May Just Have to Wait“ and ”Health Care Plan Summary of Benefits and Coverage: Still No Final Model, But Substantial Excise Taxes are Looming Anyway“) that they would soon need to address the new Summary of Benefits and Coverage (“SBC”), although urgent action would need to wait until the issuance of final guidance. Well, the wait is over. The Departments of Treasury, Labor, and Health and Human Services (the “Departments”) have published final regulations and a number of other materials to implement the disclosure requirements for group health plans and health insurance issuers related to the SBC. These materials describe the contents that an SBC must contain. Decisions need to be made regarding who will prepare SBCs, when and how SBCs must be provided, and what information must be set forth in the SBCs. The final regulations describe a number of circumstances in which either a health insurance issuer or a health plan must deliver an SBC. Employers will need to coordinate with their insurance providers to make sure these requirements are being satisfied.

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