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New Proposed Rules Streamline ACA Summary of Benefits and Coverage (SBC) Disclosure Requirement


January 2015

In a very welcome development for health insurance issuers and employers who sponsor self-funded group health plans, the Departments of Treasury, Labor, and HHS have issued joint new proposed regulations that will streamline one of the Affordable Care Act’s key disclosure documents—the Summary of Benefits and Coverage (SBC). For group health plans, the SBC was designed to give participants a simple way to review and compare terms under the different offerings in an employer’s group health plan. 

The original SBC rules, finalized in 2012, required numerous descriptions of plan features and were not necessarily helpful in allowing consumers and participants in group health plans to make informed comparisons of health coverage options. Based on feedback from employers, the insurance industry, and health insurance consumers, the new proposed rules will simplify the SBC and limit the amount of information that plan sponsors and insurers are required to disclose.

Among other things, the proposed rules will:

  • shorten the SBC from four double-sided pages to two and half double-sided pages;
  • eliminate language regarding annual limits on essential health benefits and pre-existing condition exclusions;
  • add a third coverage scenario that details the expenses that a plan participant could expect to pay for the treatment of a simple foot fracture with emergency room visit; and
  • include new definitions in the Uniform Glossary that must be referenced in the SBC.

The proposed rules incorporate guidance that the Departments have issued informally as well as in the form of FAQs since the SBC rules were finalized in 2012. In addition to publishing the proposed rules in the Federal Register, CMS has posted for comment updated documents including an SBC template, a sample completed SBCsample instructionsfor completing the SBC template, and a new uniform glossary. Once finalized, it is anticipated that the rules will be effective as of the first plan year beginning on or after September 1, 2015.

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