Blue Cross and Blue Shield of Illinois

 

 

May 3, 2013

Legislative Update
Federal Government Releases Updated FAQs on Summary of Benefits and Coverage

The U.S. Departments of Health & Human Services (HHS), Labor and Treasury on April 23 issued a series of Frequently Asked Questions (FAQs) that are intended to answer questions that states may have about Affordable Care Act-related subjects, including the Summary of Benefits and Coverage (SBC).

The FAQs provide guidance on the preparation of SBCs for use during the “second year of applicability” – defined as documents provided in connection with group health plan and group and individual health insurance coverage, beginning on or after Jan. 1, 2014, and before Jan. 1, 2015.

Topics addressed by the FAQs include:

  • Template (authorized for second year of applicability).
  • Sample completed SBC (authorized for second year of applicability).
  • No additional changes to the SBC during the second year of applicability are anticipated.
  • Safe Harbor period has been extended until Sept. 23, 2014, that meets three conditions:
    • The insured product is no longer being actively marketed;
    • The health insurance issuer stopped actively marketing the product prior to Sept. 23, 2012; and
    • The health insurance issuer has never provided an SBC with respect to the insured product.
  • SBCs must include a statement about whether the plan or coverage provides minimum essential coverage (i.e., if the coverage meets the individual shared responsibility provisions of the Affordable Care Act) and if the coverage meets minimum value requirements. 
  • If a plan or insurer is unable to modify the SBC to include information on minimum essential coverage or minimum value, it may provide such disclosures on a separate cover letter or similar statement.
  • The template and model SBC have been updated to reflect that the plan or insurer does not impose annual limits on the dollar value of essential health benefits for plan and policy years beginning on or after Jan. 1, 2014. As an alternative, the departments will allow plans and insurers to delete the row on the “Important Questions” chart regarding whether there is an overall annual limit on what the plan pays. For any questions you may have regarding SBCs, please contact your account representative.
 
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A Division of Health Care Service Corporation, a Mutual Legal Reserve Company,
an Independent Licensee of the Blue Cross and Blue Shield Association.