Employee Benefits Compliance, Summary of Benefits and Coverage

ACA FAQ 30: Use New SBC Templates in April 2017

life insurance

On March 11, 2016, the Agencies (Dept. of Labor, HHS and IRS) issued ACA FAQ 30, to clarify the intended implementation date by which health plans and insurers should start using the new Summary of Benefits and Coverage templates (SBCs) that the Agencies issued on February 26, 2016:

  • Use the new SBC template and associated documents beginning on the first day of the first open enrollment period that begins on or after April 1, 2017 with respect to coverage for plan years (or, in the individual market, policy years) beginning on or after that date.
  • For plans and issuers that do not use an annual open enrollment period, the new SBC template and associated documents would be required beginning on the first day of the first plan year (or, in the individual market, policy year) that begins on or after April 1, 2017.

ACA FAQ 30 is only one page long.  The specific section that asks and answers the question provides:

What is the intended implementation date for SBCs using the new template and associated documents?

After the close of the public comment period on March 28, 2016, regarding the proposed SBC template and associated documents that were published on February 26, 2016, the Departments intend to review the comments and finalize the new SBC template and associated documents expeditiously. The Departments intend that health plans and issuers that maintain an annual open enrollment period will be required to use the new SBC template and associated documents beginning on the first day of the first open enrollment period that begins on or after April 1, 2017 with respect to coverage for plan years (or, in the individual market, policy years) beginning on or after that date. For plans and issuers that do not use an annual open enrollment period, the new SBC template and associated documents would be required beginning on the first day of the first plan year (or, in the individual market, policy year) that begins on or after April 1, 2017.