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Buck’s SBC Solution: PPACA Summary of Benefits and Coverage Do your participants have the right information? Starting as soon as the next open enrollment period, most plan administrators will be required to furnish participants and beneficiaries with the new Summary of Benefits and Coverage (SBC) for each benefit package offered. Buck can help. Is your program simple or complex? If you offer only fully-insured health plans, your carrier likely will take care of this responsibility on your behalf. However, if like many large plan sponsors, your program is self-funded or complex, your claims administrator likely won’t have all the information required to prepare SBCs. In turn, compliance is less straightforward. Distribution and fulfillment Providing every participant — active, retired, COBRA, etc. — the right SBC at the right time in the right language and in the right format (print or electronic) will be a challenge. The new regulations have very specific requirements for when: • A separate SBC with customized claims examples must be produced • The obligation can be satisfied electronically or must be met via print distribution • The SBC can be combined with other communications • Culturally and linguistically appropriate alternatives must be provided • SBCs must be updated/modified While very prescriptive, the regulations allow for some flexibility. With advance planning and efficient use of technology and communication processes, plan sponsors can greatly reduce the overall compliance burden and help ensure the SBCs support the law’s goal of educating your employees. Health and Productivity Your compliance effort could grow significantly if you: • Use a carve-out specialty vendor for certain benefits, such as prescription drugs or behavioral health services • Offer financial incentives under your wellness program that affect plan out-of-pocket cost-sharing • Vary your contribution to an employee’s HRA or HSA based on coverage tier (e.g., single, family) or qualification for wellness incentives • Offer plans with multiple carriers • Vary your plans’ deductibles or other cost-sharing features based on salary or position • Have retiree medical plans • Have employees requiring alternate language SBCs • Need to deliver printed versions and prefer targeting (not sending all SBCs to all participants)
