Employee Benefits Compliance

Updated 2021 Summary of Benefits & Coverage; Corresponding FAQs Released

Summary of Coverage

The Departments of Health and Human Services (HHS), Labor (DOL) and Treasury (IRS) jointly issued Frequently Asked Questions (FAQs) clarifying issues related to the updated Summary of Benefits and Coverage (SBC) template for the 2021 plan year. Additionally, the 2021 SBC materials were reposted with corrections. HHS intends to release a Summary of Changes. Plans responsible for creating and distributing their own SBCs (e.g., self-funded plans) should ensure they use the latest version come their 2021 plan year renewal time. For more details on the last SBC version, see the Leavitt Group article.

Coverage Examples Calculator

Use of this calculator is not required but rather a tool to assist group health plans and insurance carriers determine the estimations needed to complete the examples portion of the SBC.

Template Use Timeframe

The 2021 SBC and related materials must be used beginning the first day of the open enrollment period for any plan year beginning on or after January 1, 2021. As a reminder, SBCs have specific deadlines for distributions.

  • With open enrollment materials or the first day eligible to enroll
  • Insured plans with automatic renewal – 30 days before
  • Within 90 days after special enrollment
  • Within seven days of request
  • Within 60 days of a material change

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