Highlights of the Summary of Benefits & Coverage Requirement

Posted by Matt Schwartz on Thu, Feb 27, 2020 @ 11:02 AM

ACA
Plan administrators of group health plans must provide a Summary of Benefits and Coverage (SBC) to eligible individuals. Insurer is responsible for creating the SBC for fully insured plans, and the insurer and plan administrator are both responsible for distributing to participants in insured plans. 

Plan administrator (which is usually the employer) is responsible for creating and distributing the SBC for self-funded plans.

There is a penalty of up to $1,000 per employee for willful (deliberate) failures to provide the SBC for violations that occurred on or before November 2, 2015 (regardless of when the penalty is imposed), and for penalties imposed on or before August 1, 2016. The penalty amount is $1,087 for penalties imposed after August 1, 2016 and on or before January 13, 2017. The penalty amount is $1,105 for penalties imposed after January 13, 2017 and on or before January 2, 2018. The penalty amount is $1,128 for penalties imposed after January 2, 2018 and on or before January 23, 2019. The penalty amount is $1,156 for penalties imposed after January 23, 2019. The penalty amount is $1,176 for penalties imposed after January 15, 2020. In addition, a $100 per participant per day excise tax may apply to each individual to whom such failure relates.

6/15/2015

Updated 9/10/2018

Updated 11/11/2019

Updated 1/14/2020

Updated 2/5/2020

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This information is general and is provided for educational purposes only. It reflects UBA's understanding of the available guidance as of the date shown and is subject to change. It is not intended to provide legal advice. You should not act on this information without consulting legal counsel or other knowledgeable advisors. 

Topics: Compliance Issues, Affordable Care Act, Employee Benefits