DOL Issues Final SBC Template and Instructions

DOL Issues Final SBC Template and Instructions

SBC_page_5_April_2017On Wednesday, April 6, 2016, the DOL (United States Department of Labor) issued final regulations on the new SBC (Summary of Benefits and Coverage) template and related documents, intended for use as of April 1, 2017. Final documents and a completed sample SBC are available on the DOL website, see the link below.

PPACA (aka the Affordable Care Act) requires insurers and plan sponsors to use SBCs as a means to provide plan participants with standard information so they can better understand and compare one medical plan to another.  (You may recall the uniform “food label” analogy we often refer to in our web-seminars).  The final SBC template and instructions keep the “material changes”  that were proposed to in late February 2016.  These changes include:

  • Streamlined content, for example, the removal of Q&A about Coverage Examples, which reduced the template to five (5) pages (SBC limit remains 8 pages/4 double-sided pages).
  • An additional cost example for a foot fracture treated in an emergency room.
  • Updated claims/pricing data for the coverage example calculator.
  • New MEC (Minimum Essential Coverage) and MV (Minimum Value) language, as well as new continuation and appeals/grievance rights language.
  • Revised language for some sections of the template.
  • An updated Uniform Glossary.

Any impact on Expatriate Plans?

No.  Both U.S. issued fully insured and self-funded expatriate plans will continue to be exempt from the SBC requirements. This new/revised template does not impact expatriate plans.


Prior guidance