SBC Regulations Finalized, Now We Wait for the Updated Template
A week ago, the DOL, HHS, and IRS issued final regulations regarding the summary of benefits and coverage (“SBC”) a group health plan must provide to participants and beneficiaries describing the benefit options they are eligible to receive. There were few changes from the proposed regulations we previously wrote about last December, but at least the Departments clarified that group health plans that enter into a contract with a third party to provide the SBC may rely on the third party without having to issue a duplicate SBC. The regulations are effective August 17, 2015, but the Departments recently scrapped their proposed, revised SBC template from December to allow for consumer testing and get input from the public. They hope to have a final template ready by January of 2016, to be used for plan years beginning on or after January 1, 2017. We will keep you updated if there are any further delays, but it looks like you should have all of 2016 to update your SBC for compliance with the final rules.