March 16, 2016
On March 14, 2016, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”), which are responsible for implementing group health plan standards under the Affordable Care Act, released a frequently asked question (FAQ) clarifying when plan sponsors must use the new SBC template that the Departments released in proposed form at the end of February 2016. The actual deadlines will be set when the Departments release the final SBC template in April 2016.
According to the FAQ, plan sponsors that have an annual open enrollment period would be required to use the new SBC template beginning on the first day of the first open enrollment period that begins on or after April 1, 2017 (for coverage beginning on or after that date). For example, if a plan sponsor conducts open enrollment in May 2017 for a July 1 plan year, the plan sponsor would need to distribute the new SBC template with the open enrollment materials prepared for that May 2017 open enrollment period.
For plans that do not have an annual open enrollment period, the new SBC template would be required beginning on the first day of the first plan year that begins on or after April 1, 2017. Under existing regulations, plan sponsors must generally distribute SBCs 30 days before the start of a plan year. As a result, for a plan year beginning on April 1, the new SBC would have to be provided by March 1, 2017.
The SBC is a standard form describing the plan’s benefits that plan sponsors must complete and distribute each year. For more information, please see the Departments’ answer to the FAQ, “What is the intended implementation date for SBCs using the new template and associated documents?”
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