One More Chance to Comment on SBC Changes

Originally posted on the CHIRblog.

Last week, the Departments of Health and Human Services, Treasury and Labor released a proposed revised template for the Summary of Benefits and Coverage (SBC), giving the public 30 days to comment before these long-coming changes are finalized. The process for implementing changes to the SBC template began in December 2014 but took a detour in March of 2015 to obtain the input of a multi-stakeholder group at the National Association of Insurance Commissioners (NAIC). As a member of the NAIC’s work group, I was pleased to see that the revised template incorporates many of the changes we recommended – some of which Navigators and assisters have said will make plan shopping easier for Marketplace enrollees.

The SBC is one of the more popular provisions of the Affordable Care Act and helps consumers to make apples-to-apples comparisons of their plan options, whether shopping on their own, in the Marketplace, or through an employer. The SBC is also designed to help consumers more easily find information to understand how their coverage works, once enrolled in a plan.

The revised template incorporates two key changes that we know will help consumers: information on the services available before an enrollee has to meet the deductible, and clearer information about how the deductible works. Many marketplace plans cover services before the deductible – last year over 80 percent of plan enrollees in the federal marketplace chose such a plan. The proposed template will help consumers more easily identify which plans include this feature. The Navigators and assisters that we work with report that consumers struggle to understand how deductibles work. In particular, consumers can’t easily find out if their deductible is embedded or non-embedded, and most don’t know what that means. For families with someone who uses much more health care than others in the family, the difference in deductible type can significantly affect how much financial protection their plan provides. The proposed template requires insurers to disclose and explain what type of deductible a plan has, so consumers can choose the plan that best fits their financial and health care needs.

The proposed template adopts other changes recommended by the NAIC work group. For a detailed summary of the changes and the timeline for this proposed template’s long path to completion, see Tim Jost’s blog. The biggest disappointment of the proposed template released last week is that it won’t take effect for Marketplace plans until 2018, a full year later than consumer advocates wanted. These changes mark a helpful step forward for the SBC and will help consumers shopping for coverage and using their plan. It’s unfortunate that they’ll have to wait longer than anyone expected when this revised template began its journey in December 2014.