Changes to the SBC Template for 2021

Plans and issuers will be required to use the new 2021 Summary of Benefits and Coverage (SBC) template in connection with coverage and plan years beginning on or after January 1, 2021. Updated instructions and other materials are also available on the agencies' websites. Specifically,

  • The new form revises the minimum essential coverage statement to reference the impact on premium tax credit eligibility, and removes the reference to the individual mandate (given the mandate has been effectively eliminated),
  • Likewise, the Uniform Glossary has removed references to the individual mandate,
  • The new template also summarizes certain different types of minimum essential coverage (although it does not explicitly refer to employer sponsored plans),
  • Related material updates include a "crosswalk" document that details changes made to the October 2019 version of the Coverage Examples Calculator.

Although the changes are not drastic, plan sponsors will want to familiarize themselves with the new template and ensure that it is used in connection with open enrollment for the 2021 plan year.

KMK Law articles and blog posts are intended to bring attention to developments in the law and are not intended as legal advice for any particular client or any particular situation. The laws/regulations and interpretations thereof are evolving and subject to change. Although we will attempt to update articles/blog posts for material changes, the article/post may not reflect changes in laws/regulations or guidance issued after the date the article/post was published. Please consult with counsel of your choice regarding any specific questions you may have.

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