Employers will need to change the summary of benefits and coverage (SBC) they provide to their employees to reflect changes in healthcare law. The Department of Labor has recently released a template SBC for employers’ use. Key changes to the SBC include new required language about whether the plan provides minimum essential coverage. Employers must also indicate whether the plan meets actuarial value requirements.
The Department of Labor has also taken measures to make transition easier for employers. First, the Department has provided sample language for required statements. It has also indicated that employers may be able to use old SBCs with a cover letter including new required language. It has also stated that it will not enforce the new requirements in other situations. Employers should use this new guidance to review their SBCs and determine whether updates are needed.
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