Burdens Relating to the Production and Distribution of the Summary of Benefits and Coverage (February 1, 2019)
The Church Alliance submitted comments to the Internal Revenue Service regarding the Summary of Benefits and Coverage (“SBC”) that health plans are required to prepare and distribute under the Affordable Care Act. The scope of the comments was generally limited to the burdens associated with collecting and assembling the information and ways in which the information could be more useful to recipients. The letter urged that church health plans be permitted to electronically distribute SBCs to current members. It also requested that SBC language translation requirements be limited and that the timing of providing an SBC to a new hire be made flexible for church plans. The overly complex nature of the claim examples in the SBC was discussed and significant simplification of these examples advocated.