A Final Rule on the PPACA Requires Changes Effective September 2012

by Michael Haberman on February 13, 2012 · 0 comments

On February 9, 2012 the government issued a set of final rules on the Patient Protection and Affordable Care Act (PPACA) that must be effective by September 22, 2012. Unfortunately if you wait that long to do anything about it you will be too late. The final rules require working with your insurance carrier and brokers to make sure that as an employer you are abiding by these requirements.

The new rules have two major elements. First, each insurer and group health plan must provide a Summary of Benefits and Coverage (SBC). Each SBC must have twelve content elements, including a description of cost-sharing requirements such as deductibles, co-insurance and co-payments, and information regarding any exceptions, reductions or limitations under the coverage. The second part of this improved communication to the consumer is a glossary of terms used commonly in health insurance coverage, such as “deductible” and “co-payment.”

According to an article produced by SHRM “The rule specifies requirements related to the appearance of the SBC, which generally must be presented in a uniform format, cannot exceed four double-sided pages and must not include print smaller than a 12-point font.” Additionally, there must be a “standardized plan comparison tool” that provided plan coverage examples. According to SHRM “The coverage examples are meant to illustrate sample medical situations and describe how much coverage the plan would provide in an event such as having a baby (normal delivery) or managing Type II diabetes (routine maintenance, well-controlled). These examples are intended to help consumers understand and compare what they would have to pay under each plan they are considering.” Reference: Administration Issues Final Rule on Summary of Benefits and Coverage by Stephen Miller, CEBS

Results of the HighRoads  Third Annual SPD Trend Survey, published by SHRM, shows that many employers are not prepared to comply with this rule, which was originally to have been effective at the end of March 2012.

According to Healthcare.gov “The SBC will help consumers better understand the coverage they have and allow them to easily compare different coverage options. It will summarize the key features of the plan or coverage, such as the covered benefits, cost-sharing provisions, and coverage limitations and exceptions. The SBC will be available to consumers at important points in the enrollment process, such as when they are shopping for coverage, when they apply for coverage, at each new plan year, and at any time upon request.” You can get further information by going to Providing Clear and Consistent Information to Consumers About Their Health Insurance Coverage. Templates for the SBC and the glossary are provided there.

Although health insurers will be producing this information it is important for each employer to understand this final rule for their group health plan. If your insurance broker has not mentioned this each employer needs to be bringing this up to them so you can be prepared for September 22, 2012

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