Feb. 8, 2017
Process FAQs: Non-discrimination Communications Addition to SBCs, OOCs and Member Booklets
This article is a follow-up to the Non-discrimination Communications Required for SBCs, OOCs and Member Booklets Per Section 1557 article published in the Jan. 25 issue.
You may have read an article regarding non-discrimination communications that were recently added to Summaries of Benefits and Coverage (SBC), Outlines of Coverage (OOC) and member booklets. In an effort to address questions you may have about this process, the following is a list of common questions received and details that may provide further insight.
This information applies to Blue Cross and Blue Shield of Illinois (BCBSIL), Blue Cross and Blue Shield of Montana (BCBSMT), Blue Cross and Blue Shield of New Mexico (BCBSNM), Blue Cross and Blue Shield of Oklahoma (BCBSOK) and Blue Cross and Blue Shield of Texas (BCBSTX).
What is the non-discrimination communication?
This two-page communication briefly outlines the rights and assistance available to members, including a resource that members can use to ask questions about their benefits in their native language.
Why is this document required to be attached to SBCs, OOCs and member booklets?
This communication has been mandated by Section 1557 of the Affordable Care Act. Per this mandate, meaningful access and non-discrimination language must be included with SBCs, OOCs and booklets prior to member distribution.
When is this requirement effective?
This requirement is effective immediately and applies to SBCs, OOCs and booklets created and distributed in January 2017 onward.
Why and when would this communication need to be attached to an SBC, OOC or booklet manually?
This communication would be manually attached to an SBC, OOC or booklet only in the event that it is not already attached to a member document when it is pulled from an online repository or if the member document is distributed outside of normal delivery methods.
How many communications need to be attached to an SBC, OOC or booklet?
One communication matching the Plan state under which the member is covered would be attached to each SBC, OOC or booklet. Example: A Texas-specific non-discrimination communication would be added to a BCBSTX SBC.
What if, for example, an employer offering Blue Cross and Blue Shield of Texas coverage has employees residing in Illinois, Montana, New Mexico and Oklahoma? Would that state’s-specific communication be added to the member’s BCBSTX booklet?
No. The non-discrimination communication attached to each member document should still match the Plan state indicated on it. So in this case, the Texas-specific non-discrimination communication would be attached to the BCBSTX booklet.
What happens if a member covered under BCBSTX, but residing in one of the other four states, requires language assistance?
The member can call the telephone number listed on the non-discrimination portion of his BCBSTX SBC, OOC or booklet and speak to a representative about the language assistance he needs. Even if the language he is seeking assistance in is not listed on the non-discrimination portion of his BCBSTX member document, the inquiry will be re-routed to a representative who can assist with that particular language.
Where can I retrieve the nondiscrimination communication to manually attach it to an SBC, OOC or booklet?
The non-discrimination communication document for Texas can be obtained by reaching out to a BCBSTX representative.
Is there a long-term solution for attaching this communication to member documents manually?
Yes. An automated non-discrimination language inclusion process is gradually being implemented for all Standard and Custom member documents. However, until this process is fully implemented, the communication will need to be manually adhered to member documents by producers prior to member distribution.
When is the automated document attachment process expected to be fully implemented for SBCs?
Non-discrimination language has been automatically implemented for Standard, Qualified Health Plan (QHP) SBCs as of the end of January 2017. Automated addition of these communications for all Custom SBCs is targeted for early February and is anticipated for completion in mid-March for Standard, non-QHP SBCs.