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Ensure Your Employees Understand Their Health Care Coverage

Affordable Care Act (ACA) requirement for employers that sponsor group health plans

As required by the ACA, health plans and employer groups must provide the Summary of Benefits and Coverage (SBC)1 to eligible employees and family members, who are:

  • currently enrolled in the group health plan, or
  • eligible to enroll in the plan, but not yet enrolled, or
  • covered under COBRA Continuation coverage.

Health Net is committed to ensuring compliance with all timing and content

requirements with regard to the distribution of the SBC. To meet this goal, you are required to provide the SBC in the exact and unmodified form, including appearance and content, as provided to you by Health Net.

Please follow the instructions below so you will know how to distribute the SBC.

SBC form and manner

You may provide the SBC to eligible or covered individuals in paper or electronic form (i.e., email or Internet posting).

  • If you provide a paper copy, the SBC must be in the exact format and font provided by Health Net, and, as required under the ACA, must be copied on four double-sided pages.
  • If you mail a paper copy, you may provide a single SBC to the employee’s last known address, unless you know that a family member resides at a different address. In that case, you must provide a separate SBC to that family member at the last known address.

For covered individuals, you may provide the SBC electronically if certain requirements from the U.S. Department of Labor are met.2

  • If you email the SBC, you must send the SBC in the exact electronic PDF format provided to you by Health Net.
  • If you post the SBC on the Internet, you must advise your employees by email or paper that the SBC is available on the Internet and provide the Internet address. You must also inform your employees that the SBC is available in paper form, free of charge, upon request. You may use the Model Language below for an e-card or postcard in connection with a website posting of the SBC:

    Availability of Summary Health Information
    As an employee, the health benefits available to you represent a significant component of your compensation package. They also provide important protection for you and your family in case of illness or injury.
    Your plan offers a series of health coverage options. Choosing a health coverage option is an important decision. To help you make an informed choice, your plan makes available a Summary of Benefits and Coverage (SBC). The SBC summarizes important information about any health coverage option in a standard format to help you compare across options.
    The SBC is available online at: <[group’s website.com]>. A paper copy is also available, free of charge, by calling the tollfree number on your ID card.

Timing of SBC distribution

If you distribute written application materials, you must include the SBC with those materials. If you do not distribute written application materials for enrollment, you must provide the SBC by the first day the employee is eligible to enroll in the plan.

For special enrollees,3 you must provide the SBCs within 90 days following enrollment.

If open enrollment materials are required for renewal, you must provide the SBC no later than the date on which the open enrollment materials are distributed. If renewal is automatic, you must provide the SBC no later than 30 days prior to the first day of the new plan year.

If your group health plan is renewed less than 30 days prior to the effective date, you must provide the SBC as soon as practicable, but no later than seven business days after issuance of new policy or the receipt of written confirmation of intent to renew your group health plan.

At the time your plan renews, you are not required to provide the Health Net SBC to an employee who is not currently enrolled in a Health Net plan. However, if an employee requests a Health Net SBC, you must provide the SBC as soon as you can, but no later than seven business days following your receipt of the request.

Notice of SBC modification

Occasionally, there will be a material change(s) to the SBCs other than in connection with a renewal, such as changes in coverage. You must provide notice of the material changes to employees no later than 60 days prior to the date on which change(s) become effective. You must provide this notice in the same number, form and manner as described above. When such changes are initiated by Health Net, Health Net will provide you with modified SBCs for distribution.

Uniform glossary

Employees and family members can access a glossary of bolded terms used in the SBC by visiting www.cciio.cms.gov or by calling Health Net at the number on the ID card to request a copy. Health Net shall provide a written copy of the glossary to callers within seven business days after Health Net receives their request.

If you have any questions, please contact your Health Net client manager.

1 26 C.F.R. § 54.9815-2715; 29 C.F.R. § 2590.715-2715; and 45 C.F.R. § 147.200.

2 Such requirements can be found at 29 C.F.R. § 2520.104b-1(c).

3 Special enrollees are individuals who request coverage through special enrollment. Regulations regarding special enrollment are found in the U.S. Code of Federal Regulations, at 45 C.F.R. 146.117 and 26 C.F.R. 54.9801-6, and 29 C.F.R. 2590.701-6.