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A Better Partnership


Jun 2012
June 04, 2012

More Clarification on the Summary of Benefits and Coverage

Updated sample documents, a calculator for completing coverage examples and no penalties for good faith attempts to comply with the Summary of Benefits and Coverage (SBC) requirements are among the topics addressed in new a set of frequently asked questions (FAQs) recently posted by the Departments of Labor, Health and Human Services and Treasury.

Under Health Care Reform, participants in employer-sponsored group health plans must receive an SBC in connection with open enrollment periods beginning on or after September 23, 2012. The SBC must be no longer than four double-sided pages in length and must provide basic information about the benefits and out-of-pocket costs associated with a health plan option

The new FAQs contain several clarifications, including:
  • An updated SBC template that corrects a typographical error
  • A calculator for coverage examples, which will soon be available here
  • SBC drafting issues where benefits are provided by multiple service providers
  • SBC templates in Spanish, Chinese, Tagalog and Navajo
  • Nonenforcement of rules for the first year for expatriate coverage
  • Special SBC distribution rules for employers with on-line enrollment systems
  • No penalties in the first year for those who are making a good-faith effort at compliance
An article that fully explains the requirements can be found here. You also may listen to our webinar on preparing an SBC.

If you have any questions about the SBC or about Health Care Reform in general, please contact Norbert F. Kugele ( or 616.752.2186), April Goff ( or 616.752.2154) or any other member of the Warner Norcross & Judd Health Care Reform Task Force.


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