Kilpatrick

Industry News

Cigna: Proposed New SBC Template Available for Final Comment

On Feb 26, 2016, the Department of Labor (DOL) issued a formal notice along with the proposed new Summary of Benefits and Coverage (SBC) template, instructions and related documents for final comment and review. Comments are due by March 28, 2016.

The Affordable Care Act requires SBCs as a means to provide individuals with standard information so they can better understand and compare medical plan offerings. Final regulations implementing SBC requirements were issued in June 2015, but release of final documents and forms was delayed to a later date. In this latest development, the DOL has released revised versions of the SBC template and other materials, based on input from the National Association of Insurance Commissioners (NAIC) and other stakeholders. The primary change in this update is due to a reinterpretation of ACA’s statute. ACA required SBCs to be no longer 4 double-sided pages. NAIC originally believed the requirement of 8 total pages was for a blank template. HHS now believes the requirement is for a completed template, thus NAIC was charged with eliminating prior content in order to make the template much leaner.

The general format of the SBC template is similar to the current version. Proposed changes to the template include:

  • Streamlined content, e.g., removal of Q&A about coverage examples, which reduced the template to 5 pages (SBC limit remains 8 pages/4 double-sided pages)
  • An additional cost example for a foot fracture treated in an emergency room
  • Updated claims/pricing data for the coverage example calculator
  • New minimum essential coverage and minimum value language, as well as new continuation and appeals/grievance rights language
  • Revised language for some sections of the template
  • An updated Uniform Glossary

The effective date for using the new template has not yet been announced. In an FAQ published a year ago, the DOL indicated that plans will begin using the new templates starting Jan 1, 2017. However, the DOL informally indicated that the new template will take effect for plan years beginning on or after Apr 1, 2017. In this scenario, calendar year plans with 1/1 effective or renewal dates would not need to use the new template until the fall 2017 enrollment period for 2018 coverage.

Links to the Notice, as well as the current and proposed SBC template, instructions and related materials are available at http://www.dol.gov/ebsa/healthreform/regulations/summaryofbenefits.html.

More complete information regarding timing and specific impacts to existing SBCs and processes will be provided after the final comment period and once final regulations are issued.

This article was adapted from an article on Cigna’s Informed on Reform website. We encourage you to bookmark Cigna’s health care reform website, www.InformedonReform.com, where they continuously update information as it becomes available.

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