Tri-Star Benefits Briefing
May 2015
New Summary of Benefits and Coverage Template Delayed
The federal government has delayed implementing proposed changes to the Affordable Care Act's Summary of Benefits and Coverage until January 2016.

On March 30, 2015 the Department of Labor (DOL) announced that the new Summary of Benefits and Coverage (SBC) template and related documents (published in proposed regulations on December 22, 2014), are delayed and will not be finalized until January 2016. However, some changes to the regulation will apply in 2015.

    What is delayed until 2016?

The DOL anticipates that the SBC template, which will go through consumer testing, will be finalized in January 2016 and will apply to 2017 coverage. It will be used for open enrollment in the fall of 2016 for plan years beginning on or after January 1, 2017. The expected changes are as follows:

  • An additional cost example for a foot fracture treated in an emergency room
  • Updated claims/pricing data for the coverage example calculator
  • New minimum essential coverage and minimum value information
  • Uniform glossary revisions
  • Removal of annual limits for essential health benefits (EHBs) information
    • What is still required for 2015?

    The following are proposed regulations that are still expecting to take effect on September 1, 2015 for plan years beginning on or after January 1, 2016:

  • • Applicability to health reimbursement accounts (HRAs) and health savings accounts (HSAs), expected benefits, expatriate coverage and Medicare Advantage plans
  • Responsible entities and their role in monitoring for compliance when designating to a 3rd party
  • The SBC must be provided at enrollment or re-enrollment

    You can read the DOL March 30, 2015 FAQ for further details.

    2016 Inflation-Adjusted Amounts for Health Savings Accounts (HSAs)

    The IRS has released the 2016 inflation-adjusted amounts for health savings accounts (HSAs). For calendar year 2016, the annual limitation on deductions for an individual with self-only coverage under a high deductible health plan is $3,350 and for an individual with family coverage is $6,750. In 2016 a “high deductible health plan” must have an annual deductible that is not less than $1,300 for self-only coverage or $2,600 for family coverage, and the annual out-of-pocket expenses do not exceed $6,550 for self-only coverage or $13,100 for family coverage.

      2016 HSA Contribution Limits:

      Individuals (self-only coverage)- $3,350 (no change from 2015)

      Family coverage - $6,750 (Up from $6,650 in 2015)

    You can find the full IRS Revenue Procedure here.

    Important Clarification Regarding Individual Out of Pocket Maximums Under Family Coverage
    On February 27, 2015, the Department of Health and Human Services (HHS) published ACA Notice of Benefit and Payment Parameters for 2016. HHS finalized clarification that “The annual limitation on cost sharing for self-only coverage applies to all individuals regardless of whether the individual is covered by a self-only plan or is covered by a plan that is other than self-only.” It also clarified that the deductible limit is NOT regulated in the same manner.

    You can find the Federal Register here (see page 77)

    This is significant because many higher deductible plans, including HSA-compatible Qualified High Deductible Health Plans (QHDHPs) previously were not written this way. Previously this meant that any one individual could be required to satisfy the entire amount of the family out-of-pocket maximum ($13,000+) before the plan covers expenses in full. This is complicated by the fact that the maximum individual amounts set under the ACA rules by HHS ($6,550) are not the same as the maximum amounts for HSA-compatible HDHPs that are set by the IRS ($6,850- see the previous article). Plan sponsors with higher out-of-pocket limits may need to address this for 2016 and make plan design changes.

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