In April, the federal government released two sets of frequently asked questions to assist group health plan sponsors and insurers with the implementation of various health care reform provisions, including the Summary of Benefits and Coverage requirements, annual limit waivers and provider nondiscrimination requirements.
The most recent set of FAQs on the SBC requirements include guidance for plan years beginning on or after January 1, 2014, and before January 1, 2015, (referred to in the FAQs as the “second year of applicability”). In the FAQs, the federal agencies clarify that additional coverage examples are not required as part of the SBC for the second year of applicability. Therefore, for the second year of applicability, plan sponsors and insurers should continue to use the same two coverage examples required under previous SBC guidance – having a baby and managing Type 2 diabetes. The FAQs also retain the good faith compliance standard for the second year of applicability for plan sponsors and insurers who are working diligently and in good faith to comply with the SBC requirements under the ACA.
