To get all the latest industry news, don't forget to visit www.passionforsubro.com.

 

Want to get involved? Share your opinion with us and comment on any of our articles.

 

Click here to read a recent article.

I look forward to seeing many of you in my travels!

Sincerely,

Andrew Milesky

Director of Client Services

 

 

 

.

This month, The Phia Group would like to place a spotlight on Keenan, who has been a client of our since 2005. Much like many of our clients, we consider many of the Keenan staff extensions of our Phia family. We truly appreciate the last 7 years of our partnership and hope to enjoy it for many more.

 Please visit http://www.keenan.com/hc/index.asp for more info.

 

"SBC Issue Outline - The Big 6"

 

Below is an outline of some of the issues.

 

(1)    Applicability:  Plans must provide the SBC, notice of modifications, and uniform summary to participants who enroll or re-enroll in group health coverage through an open enrollment period beginning the first day of the first open enrollment period beginning on or after 9/23/12 (i.e. October 1 so this will apply for November 1 plans).

 

Issue:  This is being rolled out at the busiest time of the year for renewals, the Departments failed to consider the consequences of rolling this out mid-year so as to ease both plans and administrators and insurers into the process. 

 

(2)    Interim:  Rule is issued as "final" but multiple references that this applies for "the first year of applicability only" and the "Departments intend to issue updated materials for later years." 

 

Issue:  What is the "first year of applicability" - does this mean 9/23/12 to 9/22/13 or only for 2012 or 2013 or until 2014?

 

(3)    Year One of Applicability:  Departments give plenty of materials for the first year (SBC template, samples, a guide, example calculations, etc), but there are references to all the changes with respect to coverage set to employ for 1/1/14. 

 

Issue:  Why not develop one standard template to come into effect for January 1, 2014 when all the changes will be in place instead of making multiple rounds of updates and revisions to the templates and materials.

 

(4)    Minimum Essential Coverage:  The regulations require a statement in the SBC about whether the coverage provides "minimum essential coverage" and whether the plan's share of the total allowed costs of benefits provided under the coverage meets "applicable minimum value requirements."

 

Issue:  What is "minimum essential coverage" and who decides whether "applicable minimum value requirements" have been met?  Also, the Departments "recognize" that beginning 1/1/14 new market reforms will take place and adjustments to the SBC will be necessitated.

 

(5)    Coverage  Examples:  One two types of coverage examples are contained (1) having a baby (normal delivery) and (2) managing type 2 diabetes (routine maintenance).  Breast cancer was removed.  Comments to the interim regulations suggested that "coverage examples facilitated individuals' understanding of the benefits and limitations." 

 

Issue:  Examples are still convoluted and costly to prepare.  Samples and guidance will not minimize this issue.  Further, the Departments advise that they will add coverage examples and make other changes after the first year of applicability.

 

(6)    Stand-alone or Incorporated:  Prior guidance advised the SBC must be a stand alone, but now the Departments authorize the SBC to be a stand-alone document or in combination with other summary materials (i.e. SPD) if the SBC information is intact and prominently displayed at the beginning of the materials (i.e. immediately after the Table of Contents in an SPD).

 

Issue:  Does this mean that if a self-funded plan wants to incorporate instead of a stand-alone document they must restate the plan (i.e. an amendment is not an option)?  Having the information incorporated will also create mass confusion - terms, coverage examples, etc.