Date Set for Use of New SBC Template
    03/16/2016

    On March 11, 2016, the Departments of Labor, Health and Human Services, and the Treasury (the “Departments”), jointly issued an FAQ providing the deadline by which health plans and issuers will have to use a new Summary of Benefits and Coverage (‘SBC”) template (and corresponding documents).

    For plans and issuers that maintain an annual open enrollment period, this deadline is the first day of the first enrollment period that begins on or after April 1, 2017 with respect to coverage for plan (or individual policy) years beginning on or after that date. For plans and issuers that do not have an annual open enrollment period, the deadline for use of the new template (and corresponding documents) is the first day or the first plan (or individual policy) year beginning on or after April 1, 2017.

    The FAQ providing this deadline follows the Departments’ request for public comments on the revised SBC template and associated documents that was issued on February 26, 2016. The proposed updated documents can be found HERE. Public comments are due on March 28, 2016 and the Departments have stated that they will issue the final SBC template and documents quickly after the comment period closes. Since a deadline for use of the final template was set prior to a final template being in place, all we can hope is that the government acts faster than it has in the past when finalizing other ACA provisions and documents!

    By csmith / Source: EBIA

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