The current draft of the proposed summary of benefits and coverage (SBC) could change greatly over the next few months.
“We expect that the employee benefits community and health insurers will rigorously object to many aspects of the proposed rules,” Mark Holloway, a health reform advisor at Lockton Companies L.L.C., Kansas City, Mo., says in a comment on the SBC draft and a related document, a health benefits glossary.
Agencies at the U.S. Treasury Department, the U.S. Labor Department and the U.S. Department of Health and Human Services have developed the drafts to implement Section 2715 of the Patient Protection and Affordable Care Act of 2010 (PPACA).
The proposed SBC template would create a model for a 4-page document that is supposed to be to health insurance what nutrition labels are to milk. The SBC is supposed to explain a plan’s cost-sharing provisions and limits on coverage, and it also is supposed to show what the breakdown of out-of-pocket costs might for a plan member who faces a scenario such as dealing with diabetes or having a baby.
The glossary gives definitions of terms such as “deductible” and co-payment.
For now, at least, the compliance date is set to be March 23, 2012.
“The new rules and templates appear best designed for standard insured programs, and present some difficult issues for employer plans,” Holloway says.