A benefits group wants federal agencies to require the new health plan summary descriptions to go to a tightly focused group of people.
The Employers Council on Flexible Compensation (ECFC), Washington — a group that represents insurers, plan administrators, professional advisors, and others with an interest in the flexible spending account (FSA) market, the health reimbursement arrangement (HRA) market and other benefit account markets — has made that case in a comment letters sent to the Employee Benefits Security Administration (EBSA), an arm of the U.S. Labor Department that is responsible for helping to implement many of the provisions in the Patient Protection and Accountable Care Act of 2010 (PPACA) that affect employee benefit plans.
EBSA is working on proposed regulations relating to a Summary of Benefits and Coverage (SBC), which would implement PPACA Section 2715, a provision that calls for federal regulators to create a standardized health plan description system.
Regulators want consumers to be able to use SBCs to compare plan provisions such as deductibles and co-payments, and also to help consumers compare what the total and itemized out-of-pocket costs might be for patients dealing with conditions such as pregnancy or diabetes
The proposed regulations require group health plans and health insurers to start providing SBCs March 23, 2012.
Many groups have argued that the SBC program start date is coming too soon.
John Hickman, chairman of the ECFC technical advisory committee, writes in the group’s comment letter that the ECFC would like to see EBSA postpone the start date until the “annual enrollment period for the first plan year that begins on or after the date that is one year after the final regulations are issued.”
“Sufficient time is required to digest and identify the full impact of the new legal requirements on current enrollment systems and procedures,” Hickman says.
The current start date is just 5 months away, and final regulations are not yet available, Hickman says.
The natural way to apply the new rules would be to have them take effect for the next annual enrollment period starting after the final regulations are available, Hickman says.