Our firm uses a rate aggregation tool to pull SBCs that are required to be sent to employees considering enrollment in a medical plan. Most of the tools that we use provide the SBC with no plan year or use the calendar year on the SBC instead of the actual plan year for the client. Is there a requirement that the SBC include a date? Could it include just the year, or is it required to be the actual plan year that matches the Medical Plan?
The Department of Labor requires that the SBC must show the beginning and end dates for the applicable coverage period in the top right hand corner of the first page of the SBC. If the coverage period end date is not known when the SBC is prepared, the plan or issuer is permitted to insert only the beginning date of the coverage period (e.g., “Coverage Period: Beginning on or after 01/01/2022”).
The dates listed for the coverage period may reflect the coverage period for the plan or policy as a whole, not the period applicable to each individual. Therefore, if a plan is a calendar year plan and an individual enrolls on January 19, the coverage period is permitted to be the calendar year. Plans and issuers are not required to individualize the coverage period for each individual’s enrollment.
If a plan has a plan year that differs from the benefit year – for example, the plan year begins Oct. 1, but the benefits (e.g. deductibles and out-of-pocket limits) reset on Jan. 1 – the plan or issuer may choose, based on a determination of what is most relevant to the consumer, to reflect the coverage period as either the plan year or the benefit year.
If the SBC is being provided to satisfy the notice of material modification requirements, the plan or issuer must show the beginning and end dates for the period for which the modification is effective. For example, for a change effective March 15, 2021, and a plan year beginning on January 1, 2021, and ending on December 31, 2021: “Coverage Period: 03/15/2021 – 12/31/2021”.