The U.S. Department of Labor (DOL) has issued an updated template Summary of Benefits and Coverage (SBC), Glossary of Coverage and Medical Terms, and related materials. The revised materials remain in proposed form, but have been sent to the U.S. Office of Management and Budget with a request that the templates and glossary be approved for three years. It is expected that these revised documents will replace the model SBC template and glossary that the DOL previously issued in December 2014.

According to an earlier set of DOL Frequently Asked Questions, these revised documents will apply to coverage that renews or begins on or after January 1, 2017. However, the DOL has informally indicated that the effective date will be delayed to apply to plan/policy years beginning on and after April 1, 2017 (and the annual enrollment periods leading up to them. We expect further guidance to that effect.

The SBC is a precisely formatted document that group health plans and health insurers are required to provide in connection with enrollment and re-enrollment periods. In addition to technical changes, the revisions require the SBC to describe services covered by the plan prior to meeting a deductible and to add a third example on the costs associated with the simple fracture of a bone.

As the federal health care reform effort gained steam, Ballard Spahr attorneys established the Health Care Reform Initiative to monitor and analyze legislative developments. With federal health care reform now reality, our attorneys are assisting health care entities and employers in understanding the relevant changes and planning for the future. They also have launched the Health Care Reform Dashboard, an online resource center for news and analysis on developments under the Affordable Care Act.