New Summary of Benefits and Coverage Required for Health Plans in 2012

Morgan Lewis
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On August 22, the Departments of Treasury, Labor, and Health and Human Services (the Departments) jointly published proposed regulations on the new Summary of Benefits and Coverage (SBC) that insurers and group health plan administrators will be required to distribute beginning next year. The SBC is intended to provide clear and consistent information that will enable employers and participants to compare and understand the costs and benefits of different health coverage options.

The Patient Protection and Affordable Care Act (PPACA) requires that insurers and group health plans (whether or not grandfathered) provide an SBC for each coverage option offered by the insurer or plan.

The Departments have proposed a template for the SBC, as well as a separate uniform glossary of terms commonly used to describe health coverage, such as “co-pay” and “deductible.” The new SBC requirements are proposed to apply as of March 23, 2012, although the Departments signaled in the proposed regulations that “practical considerations might affect the timing of implementation.”

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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