Changes affecting the coverage examples

The coverage examples page of the SBC simulates how much a participant would have to pay “out of pocket” based on the plan’s actual cost-sharing requirements under three hypothetical treatment scenarios: having a baby, managing type 2 diabetes and foot fracture with a trip to the emergency room. Although these treatment scenarios are not new, HHS has updated the underlying cost data that must be used to run the simulations. As a result, even without any change in the plan’s design, every SBC will need new calculations for the coverage examples section.

Act now to meet the approaching deadline

Plan sponsors with calendar-year plans that have a fall open enrollment period are required to distribute the new SBC template with open enrollment materials.

For plans that do not have an annual open enrollment period, plan sponsors must generally distribute SBCs 30 days before the start of the plan year. As a result, for a plan year beginning January 1, 2021, the new SBC would have to be provided by December 1, 2020.

Given the new required calculations for the coverage examples, it is not too early to get started on SBC for 2021. Acting soon is especially important if your organization relies on outside professionals to update your SBCs.

If your organization uses third-party administrators to complete your SBCs, now is a good time to ensure that those administrators are familiar with the new template and the need to update all calculations on the coverage examples page.