The ongoing debate about health care reform has stirred up much “dust.” As it continues to settle, it’s vital that you remain informed about being prepared for the DOL’s new health care reform and the related Summary SBC (Summary of Benefits) template.
Knowing where we’ve been
In 2016, the Departments of Labor, Treasury, and Health and Human Services initiated changes based on their responsibilities under the Affordable Care Act (ACA). A key change had to do with the SBC template and the instructions for completing the SBC.
New rules and obligations for plan sponsors apply based on their individual SBC’s. The SBC template changes have been labeled “significant.”
Changes affect plan sponsors and third-party administrators. It’s necessary to be informed as you go forward.
Getting to where you need to go
Here’s where your understanding (to date) should land:
- SBC’s require fully insured carriers and plan sponsors (of self-insured group health plans) to use HHS (Health and Human Services), calculators. Calculations are focused on the minimum value of the health plan. Each calculation determines whether or not it meets the minimum 60% standard required by law.
- A “Yes” or “No” answer is required for the FAQ and the new SBC template related to whether the plan meets minimum value.
- Your determination and subsequent answers on the SBC could remove the uncertainty for employers concerned about the minimum value percentage for their particular plans.
- Employers must implement plan design changes if their plans do not meet the requirement. Failure to do so will incur penalties as stated under Code Section 4980H(b).
Contact us with your questions about Health Care Reform and your employer’s obligations.