For plan years beginning on or after January 1, 2021, plan sponsors must use the updated Summary of Benefits & Coverage (SBC) template, and related materials. The Departments of Labor (DOL) and Health and Human Services released these updated materials for the SBC in November 2019. Under the Affordable Care Act (ACA), most health insurers and group health plans are required to provide an SBC to individuals eligible for or enrolled in the plan.
This is the first update to the template and accompanying documents since 2017.
The SBC is mandated under the Affordable Care Act (ACA) and is a four-page document template that all plans must provide to participants. In most cases, the insurance carrier or Third-Party Administrator (TPA) will create these on behalf of the plan sponsor. But for self-funded plans, including some Health Reimbursement Arrangements, plan sponsors themselves may be responsible.
Changes to the New Templates
The update includes several minor formatting changes, in addition to some minimal substantive changes.
Minimum Essential Coverage
This section is revised to reflect the elimination of the individual mandate payment.
Prior templates stated that individuals without Minimum Essential Coverage (MEC) may have to make a tax payment. That section now indicates that individuals eligible for certain types of MEC may not be eligible for a premium tax credit.
It now summarizes the types of coverage that may constitute MEC.
This section that now includes "not applicable" in addition to yes and no as an answer option whether the plan provides. In addition, it now states that minimum value is not relevant for individual coverage.
Minimum Value
This section that now includes "not applicable" in addition to yes and no as an answer option whether plan provides. In addition it now states that minimum value is not relevant for individual coverage.
Action Required

Plan sponsors obligated to complete and distribute the SBC themselves (self-funded and account based plans) should familiarize themselves with these changes. The latest versions of the SBC are released in final form. Any changes relate to the elimination of the individual mandate payment. Unfortunately, the new materials have not cleared up confusion for account-based plans or whether "good faith" compliance standards will be accepted as they were in the past.

For complete details on the new SBC and its related materials, see the DOL webpage below:

www.dol.gov/agencies/ebsa/laws-and-regulations/laws/affordable-care-act/for-employers-and-advisers/summary-of-benefits

Sample Summary of Benefits and Coverage for HRAs, click on the link below:

HRA SBC

Sample Summary of Benefits and Coverage for ICHRAs, click on the link below:

ICHRA SBC

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