New Proposed Regulations for Summary of Benefits and Coverage (SBC)

On Dec. 22, 2014, the U.S. Departments of Health and Human Services, Labor and the Treasury (Departments) released proposed regulations regarding the summary of benefits and coverage (SBC). The proposed regulations would amend the final SBC regulations from Feb. 14, 2012.

Also released were a proposed SBC template, instructions, uniform glossary and other materials. According to the Departments, the proposed changes are designed to improve consumers’ access to important health plan information, as well as to provide clarifications that will make it easier for group health plans and health insurance issuers to comply with the SBC requirement.

Overall, the proposed modifications would:

  • Clarify when and how a plan or issuer must provide an SBC;
  • Streamline and shorten the SBC template;
  • Add certain elements to the SBC template that the Departments believe will be useful to consumers.

The new template, instructions and supplementary materials are available on the DOL’s website under the heading “Templates, Instructions, and Related Materials – Proposed (SBCs On or After 9/15/15).”

In addition, the proposed regulations would make some of the SBC enforcement safe harbors and transitions permanent, with several modifications.

The Departments invite interested parties to submit comments on the proposed regulations and documents required for compliance (including the template, instructions, sample language, coverage example calculators and the uniform glossary).

If the proposed regulations are finalized, the Departments expect the new requirements for the SBC and uniform glossary would apply to coverage that begins on or after Sept. 1, 2015.



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The information provided is for informational purposes only and does not constitute legal advice. The information above contains only a summary of the applicable legal provisions and does not purport to cover every aspect of any particular law, regulation or requirement. Depending on the specific facts of any situation, there may be additional or different requirements. This is to be used only as a guide and not as a definitive description of your compliance obligations.