Health Insurance Exchange and Revised COBRA Model Election Notices Released

The Affordable Care Act (ACA) added a section to the Fair Labor Standards Act (FLSA) that said an applicable employer must provide a written notice to each existing employee no later than March 1, 2013, and to new hires beginning on that date. But on January 24, 2013, the Department of Labor (DOL) put out an FAQ that recognized that was an unrealistic deadline.

On May 8, 2013, the DOL provided an update with temporary guidance and templates of the required Exchange Model Notices (For Employers who offer a health plan and Employers who do not offer a health plan) and the Revised Model COBRA Election Notice. Starting on October 1, 2013, the notices have to be given to new employees on the day they are hired. The notices have to be given to existing employees no later than October 1, 2013.

The notices, along with further guidance, can be found at www.dol.gov/ebsa. Please review the attached Health Care Reform Hot Topic for more information on the Model Notices Explanation.

Departments Issue FAQ on Summary of Benefits & Coverage Changes

On Tuesday, April 23, 2013, HHS, Treasury and the DOL published Part XIV of their FAQs on the Affordable Care Act, focusing on revisions to the Summary of Benefits and Coverage (SBC).

 

The seven-question FAQs introduce two primary changes, which take effect for plan years starting on or after January 1, 2014:

• A statement indicating whether a plan provides minimum essential coverage (MEC)
• A statement answering whether the plan's share of the total allowed costs of benefits meets applicable minimum value (MV) requirements (i.e., at least 60 percent of allowed charges for covered services, also known as bronze level coverage)

Plans may provide this information by either updating their SBCs or providing it in a cover letter. The departments provided sample language in the FAQs. In addition, the SBC template has been updated as well as the sample completed SBC. The uniform glossary remains unchanged.

 

In a previous notice, the departments indicated that more wholesale changes would be likely for 2014, including revisions and additions to the coverage examples. However, these FAQs confirm that the MEC and MV statements are the only required changes. Also, much of the transition relief provided in 2013 has been extended to 2014. See Q/A-5 in the FAQs for additional details.

 

FAQs about the the Affordable Care Act Implementation Part XIV

 

Original article courtesy of Infinisource:  http://newsroom.infinisource.com/post/2013/04/25/Departments-Issue-FAQ-on-Summary-of-Benefits-Coverage-Changes.aspx

Health Care Reform Update – Summary of Benefits and Coverage

Effective for plan/policy years and open enrollments (OEs) beginning on or after September 23, 2012, health insurers and self-insured group health plans will be required to provide a standard Summary of Benefits & Coverage (SBC) to enrolled members.

The group administrator is responsible for distributing SBCs to plan participants at least 30 days prior to renewal date (during the first day of OE), at initial enrollment, during special enrollments, 60 days prior to a material modification, and upon request.

Under the SBC requirements, willful failure to comply could result in up to a $1,000 fine per plan participant or beneficiary for each failure. HHS or the DOL can also issue an additional fine of $100 per day per affected person until the SBCs are properly issued.


For a more comprehensive overview on SBCs, please review the Reform Update 10/1/2012 - SBC Explanation and the SBC Sample. Current clients can log in to MyBasicGuru to access the Employer Notifications Checklist & Guide as well as Carrier specific information and instructions on obtaining SBCs.