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What the Summary of Benefits and Coverage Deadline Delay Means for Health Plans

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On November 17, 2011, the Departments of Health & Human Services, Labor, and the Treasury (the “Departments”) issued an FAQ document that addressed the concern of many health plans about being able to meet the proposed March 23, 2012 deadline for the summary of benefits and coverage (SBC) requirement that is part of the Patient Protection and Affordable Care Act (PPACA).

The document states that health plans are not required to comply with the regulation until final regulations are issued. As of today, the Departments have not yet issued final regulations, and there is no word on the final release date. While the Departments’ FAQ may have eased concern over the tight deadline, they may have raised additional questions for health plans on how they should implement given an extended timeframe.

Most health plans have come to the same conclusion about the SBC regulation: as one recent prospective VUE Software client put it, “This is a software issue”. Plans have recognized that in order to comply with various aspects of the SBC, an automated solution is necessary. Previous to the deadline extension communication, many health plans were scrambling to find a vendor who could assist, feeling pressured into making hasty decisions on important investments.

Now, plans have more time to figure out how to go about acquiring the right software for the SBC. Many who were considering building a solution in-house may have the time to do so with a looser deadline. Still, with no final regulations, many development efforts may be wasted trying to hit a moving target. And, since the Departments have stated neither the final regulation release date, nor the duration between time of issue and new deadline, health plans who wait to begin implementation until after the regulations are issued may find that they still don’t have enough time to meet the new deadline.

With such uncertainty, smart health plans will take the extended deadline lightly, and move forward on implementing a flexible infrastructure that will allow them to comply with the final regulations, no matter what their final form. For more information on VUE Benefit Summary Tool, which functions both as a flexible infrastructure for storing plan data and creating benefit summaries – and comes out-of-the-box with the current format for SBCs and includes free updates to future formats –register now for an informational call with a product consultant.



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