Summary of Benefits and Coverage deadline is two months away for some plans
After the Supreme Court’s historic upholding of the Affordable Care Act (ACA), U.S. employers are looking at the next set of milestone regulations and seeking the most efficient way to comply. A major requirement – just several months away – is the Summary of Benefits and Coverage (SBC), required to be in effect for open enrollment periods beginning on or after September 23, 2012. HighRoads, a benefits management organization, notes that employers must have SBCs in place not only for the plan an employee is enrolled in, but for all plans for which that employee is eligible.
SBCs are meant to benefit employees by creating “clear, understandable and straightforward information on what health plans will cover, what limitations or conditions will apply, and what they will pay for,” according to the U.S. Department of Health and Human Services.
“Under the SBC regulations, as an employee, I am entitled to an SBC for my enrolled plan but I must also be able to view the SBC for any plan I am eligible for. In corporations with multiple plans and many employees, it is an enormous logistical and communications challenge,” said Kim Buckey, principal, Compliance Communications Practice, HighRoads.
The Supreme Court decision has given a measure of certainty to employers in planning for the future, and employers welcome this certainty,” said Tom Barker, partner in Foley Hoag. “That being said, employers have a tough road ahead, as public opinion polls continue to show a widespread lack of understanding over what the law means for most people. This means that employers will need to continue to communicate aggressively and clearly with employees over their options in the coming months.”
Tasks for employers. In the next few weeks HighRoads recommends employers focus on these four key tasks when it comes to SBCs:
|1.||Evaluate your plan design – evaluate what plans you currently have and where you can consolidate SBCs.|
|2.||Decide who will produce your SBCs – time is of the essence. Figure out who will handle your SBCs and who will provide the data needed to complete them.|
|3.||Create your communication plan – The SCOTUS decision was a landmark case. Employees will have many questions, and clear, informed communication to employees is essential. Be sure to provide some context — explain what the employee should do with the SBC and why it’s important now (and why it will be in the future).|
|4.||Maximize your distribution methods – SBCs follow ERISA electronic distribution regulations – you will need to distribute and track these documents. And, if employees do not regularly have access to a computer as part of their jobs, you must obtain their consent to receive the materials electronically. Using an automated delivery and tracking method is the optimal way to meet compliance regulations and most importantly, ensure your employees are receiving the needed information.|
“Now is the time to begin work in earnest on SBCs, to finalize 2013 plan designs, and to prepare a communication strategy that encompasses not only this fall’s open enrollment but the impact of exchanges in 2014,” added Buckey.