The Centers for Medicare and Medicaid Services (CMS) has revised the Summary of Benefits and Coverage (SBC) materials for plan and policy years that begin on and after January 1, 2021. The templates reflect the elimination of the individual mandate requirement. The new SBC forms and materials can be found here.
As you are aware, the Affordable Care Act (ACA) requires group health plans and health insurance issuers offering group or individual health insurance coverage to issue an SBC that "accurately describes plan benefits or coverage." In addition, groups must make a uniform glossary available to participants and beneficiaries.
Some of the new changes include, but are not limited to:
- Minimum Value: A “Not Applicable” answer option (in addition to the current “Yes” and "No” options) has been added to the question “Does this plan meet the Minimum Value Standards?” “Not Applicable” should only be used for individual coverage.
- Minimum Essential Coverage: The text under the heading, “Does this plan provide minimum essential coverage?” now includes a description of minimum essential coverage. In addition, a reference to the requirement to have health coverage (the individual mandate) has been eliminated from this section. The section now contains the statement: “If you are eligible for certain types of minimum essential coverage, you may not be eligible for the premium tax credit.”
There were also changes to the Uniform Glossary section of the SBC which references the elimination of the individual mandate.
Plans and issuers will be required to use the 2021 SBCs on the first day of the first open enrollment period relating to coverage for any plan year that begins on or after January 1, 2021.