The Department of Labor just released yet another FAQ explaining some of the finer points of the health reform law’s requirement that health plan sponsors provide beneficiaries with a Summary of Benefits and Coverage (SBC). Here’s what you need to know.
- Electronic copies are OK. The DOL’s new FAQ says plan sponsors are allowed to provide health plan participants with electronic SBCs in connection with their online enrollment or renewal of coverage. SBCs can also be provided electronically to participants and beneficiaries who request one online. But in any case, plan sponsors must offer the option to receive paper SBCs.
- SBCs must be provided upon application. The FAQ states insurance plans or issuers must provide an applicant with an SBC “as soon as practicable,” but no later than seven business days after receiving a “substantially complete application” for a health insurance product.
- When changes occur. If the information required to be in the SBC changes (generally due to negotiations about coverage that take place after an application is submitted), an updated SBC is not required to be provided until the first day of coverage, unless an updated version is requested earlier.
- OK to reference other documents. As long as the SBC — on its own — contains all the info required of it under the healthcare reform law, it can include a reference to another document in the SBC footer (including reference to a summary plan description). An SBC can also refer to specific pages in other documents to supplement or elaborate on the information it contains.
Info: For our breakdown of the last FAQ on the Summary of Benefits and Coverage requirement, click here.