Delay of Summary of Benefits and Coverage Requirements
by admin - December 12th, 2011.Filed under: Groups (100+ Employees), Groups (2-50 Employees), Groups (51-99 Employees). Tagged as: grandfathered plans, group health insurance, health insurance reform, Summary of Benefits and Coverage, Uniform Glossary of Terms.
Because the Patient Protection and Affordable Care Act’s Summary of Benefits and Coverage (SBC) and Uniform Glossary requirements are yet to be clearly defined, the Department of Labor (DOL) submitted guidance that has delayed the effective date of these changes, therefore causing concern of a new compliance date. As described in a previous reform blog article, the SBC is intended to provide insured members with information about the plan they have or can be used when shopping for coverage and comparing plans. The Uniform Glossary is designed to help consumers have a better understanding of terminology when making a buying decision. The DOL, Internal Revenue Services (IRS) and the Department of Health and Human Services (HHS) had originally proposed March 23, 2012 as the compliance date. Due to the delay, a new compliance date is yet to be chosen. The guidance stated that, “until final rules are issued on this topic, group health plans and health insurance issuers are not required to comply.”
There is now some concern about having enough time between the final ruling and the compliance date. The National Association of Health Underwriters (NAHU) suggested that once the final rule has been announced, employers and insurers be given an additional 18th months to comply. NAHU feels that, “based on informal comments from the administration on this topic, it seems more like that a final rule will be issued within the next few months, with compliance potentially expected by January 1, 2013.” According to the DOL, it is anticipated that the once Departments’ final regulations are issued, it will include an applicability date that gives group health plans and health insurance issuers sufficient time to comply.
What does this mean to you?
Due to the large amount of information given in these two documents, there is a concern growing about having enough time for implementation along with a compliance date. Essentially, this gives a reprieve to the carriers in complying with this requirement under PPACA. This again suggests that the implementation of many aspects of reform will continue to challenge the government to achieve it’s own expectations of meeting unrealistic timelines.