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The New Summary of Benefits and Coverage Document: Health Care Reform’s Four-Page Summary Requirement

August 25, 2011

The agencies jointly charged with implementing many of the requirements under health care reform have issued proposed regulations and related guidance regarding the four-page summary of benefits and coverage that group health plans (including grandfathered plans) will be required to provide beginning on March 23, 2012. The proposed regulations refer to this summary as the Summary of Benefits and Coverage (SBC).  In reality, this SBC is an eight-page summary; the agencies have interpreted four pages as four double-sided pages.  These proposed regulations have addressed some long-anticipated guidance, but the process is not complete.  The agencies have requested comments on the Summary of Benefits and Coverage with a comment deadline of October 21, 2011.  It is quite possible that the SBC template and related materials will be modified as a result of requests and comments made prior to this date.

 

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