Employers and their benefits advisors may have to scramble to start using the proposed Summary of Benefits and Coverage (SBC) and a proposed Uniform Glossary on time.
Members of the employee benefits and executive compensation group at Ballard Spahr L.L.P., Philadelphia, a law firm, have included that observation in a comment on draft versions of the SBC and the glossary.
Federal agencies – the Internal Revenue Service (IRS), an arm of the U.S. Treasury Department; the Employee Benefits Security Administration (EBSA), an arm of the U.S. Labor Department; and the Centers for Medicare & Medicaid Services (CMS), an arm of the U.S. Department of Health and Human Services (HHS) – posted the drafts on the Web last week.
The agencies developed the SBC and glossary drafts to implement Section 2715 of the Patient Protection and Affordable Care Act of 2010 (PPACA).
PPACA Section 2715 calls for the parent departments of the IRS, EBSA and CMS to work with the National Association of Insurance Commissioners (NAIC), Kansas City, Mo., to develop SBC and glossary standards. The agencies say they based the SBC and glossary proposals almost entirely on drafts created by the NAIC.
The proposed SBC template includes items such as descriptions of cost-sharing provisions and limits on coverage, and a detailed list of what a consumer might have to pay for the services associated with a scenario such as having a baby or dealing with diabetes.