As part of my show-and-tell, I passed around the sample SBC that the Department of Labor posted on its website. The first reaction was, “This looks like the information you receive with a credit card approval letter [that no one reads].” As the ever-professional, I simply said, “yes, it’s pretty detailed” but on the inside I was saying something more like, “wasn’t the intent of this to make the communication of medical insurance coverage easier?”
Have you seen your SBC yet? Here is the sample provided by the Department of Labor: http://www.dol.gov/ebsa/pdf/SBCSampleCompleted.pdf.
I’ll leave the judging to you but just a few comments about the SBC (or what the federal government refers to as the “easy-to-understand summary about a health plan’s benefits and coverage.”):
* The SBC may not exceed four pages in length. Convincing employees to read four pages wouldn’t be so bad, right? But the regulations from February 12, 2012 contain two extra words that make a huge difference: “cannot exceed four double-sided pages.” (emphasis my own.) Eight pages of medical benefits stuff! Call in the employee engagement police! And just for kicks, the word count in the sample SBC is 2,671 words.
* If you provide an annual health & welfare insurance benefits guide to employees (typically around open enrollment), you will most likely have your work cut out for you. Here’s why. There’s a good chance you include information about the company’s medical insurance plan options in that guide. So, will you continue to create that guide as is and offer the SBC along with it (causing employees to wonder why they are receiving two different sources of medical insurance information) or will you remove the medical insurance information from the guide and provide the SBC along with it (causing employees to wonder where the medical insurance information went and then why the medical insurance information in the SBC looks different than the rest of the health insurance information in the benefits guide) or something else? Any way you look at it, there is a good chance for some level of confusion when distributing the SBC in a population used to receiving a comprehensive health & welfare insurance benefits guide.
* If you haven’t checked the list on this website published by The Center for Insurance Information & Insurance Oversight — http://cciio.cms.gov/resources/factsheets/clas-data.html — you may want to, especially if you are developing your own SBCs. Section 2719 of the Public Health Service Act requires group health plans and health insurance issuers offering health insurance coverage to provide the SBC in a “culturally and linguistically appropriate manner.” Thus, if you operate in a county in which 10% or more of the population is literate in only the same non-English language, English versions of the SBCs must include a prominently displayed statement in the applicable non-English language indicating how to access the language services provided by the plan or issuer. Upon request, a written translation in the non-English language of applicable notices must be provided. The list on the website includes all of the counties which currently meet or exceed the 10% threshold. This list will be updated annually.
Ed Bray, J.D., is director of employee benefits for a major transportation company in Hawaii. This article originally ran on Employee Benefit News, a SourceMedia publication.