Last week, the U.S. Department of Health and Human Services (HHS) unveiled its highly anticipated final rule detailing required consumer-friendly benefit summaries and cost comparison tools, as required under Section 2715 of the Affordable Care Act. It is expected that more than 160 million Americans with private health insurance will receive the forms. The goal of the final rule is to set the design for easy-to-understand forms describing health insurance benefits in plain-English terms, with an accompanying standardized glossary. All carriers offering group and individual plans, along with group health plans must supply these documents “when shopping for coverage, enrolling in coverage, at each new plan year, and within seven business days of requesting a copy from their health insurance issuer or group health plan.” Requiring that benefit summaries use a single standard format will help consumers make an “apples to apples” comparison among health plans and result in more informed health plan choices.
Although the health system overhaul itself continues to divide the public, a major poll last year found that 84 percent of Americans support these benefit summaries. The general compliance effective date for both carriers and health plans is September 23, 2012, which is a change from the March 23, 2012 date in the proposed rule. Many carriers were concerned that the earlier date would not give enough time to implement the requirements, which likely includes extensive changes to current IT systems. The September date gives carriers more time for system updates, while giving consumers the new information in time for the popular fall annual open enrollment periods.
Another change from the proposed rule is that enrollee-specific premium amounts are not required as part of the benefit summaries. This is due in part to the large administrative burden required to provide such information that may change throughout the enrollment process.
The final rule continues to require large employer plans, including self-funded plans, to be subject to the requirements, despite heavy push-back from large employers insisting that their plans already supply employees with the benefit summaries they need. The law also requires the forms to give examples of specific coverage explaining how much a plan pays on average for common medical conditions. The initial two medical conditions chosen by HHS are pregnancy and type 2 diabetes. Over time, HHS plans to require four additional coverage examples be included in the forms.
Template for the Summary of Benefits and Coverage and Glossary

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