In order to address the details of the embattled health reform law, the U.S. Department of Labor has released a new FAQ regarding the requirement of plan sponsors to provide beneficiaries with a Summary of Benefits and Coverage (SBC). The update clarifies several key points:
• Plan sponsors are allowed to disperse SBCs electronically to plan participants when they enroll or renew online. An electronic SBC may also be provided in the case that a participant or plan beneficiary requests one online. However, the option to receive a paper SBC must be offered by the plan sponsor at all times.
• Insurance issuers must supply an SBC to all applicants at the time of application, or in the words of the DOL “as soon as practicable,” which translates into no more than seven business days after receiving a “substantially complete application” for a health plan.
• If information in the SBC changes a new SBC need not be provided until the first day of coverage under those changes unless a new version is directly requested by a participant.
• The SBC may reference other documents if all of the lawfully required information is also contained within the SBC. An SBC may refer to other documents as supplementary information or to further elaborate on information contained in the SBC.
The new FAQ is available in its entirety at DOL.gov.