On April 23rd, the DOL, HHS and IRS (the “Agencies”) released an updated template for the Summary of Benefits and Coverage (“SBC”) that group health plans and issuers are required to send to plan participants. This updated SBC is the template to be used by plan sponsors and issuers to comply with the SBC requirements for the “second year of applicability”; i.e., for coverage beginning on or after January 1, 2014 and before January 1, 2015. The good news is that the new SBC is largely the same as the template issued by the government for the “first year of applicability.” The key differences are that the new document includes statements regarding whether a plan provides “minimum essential coverage” and whether the coverage meets the “minimum value” standard under the Affordable Care Act. The existing guidance on the means of distribution of SBCs (through electronic and other means) has not changed from last year. The new template, sample completed SBC and related FAQs are available at the following links:

http://www.dol.gov/ebsa/pdf/correctedsbctemplate2.pdf

http://www.dol.gov/ebsa/pdf/CorrectedSampleCompletedSBC2.pdf

http://www.dol.gov/ebsa/faqs/faq-aca14.html