Summary of Benefits Safe Harbor

HR Policy Association strongly opposes the duplicative requirements of PPACA’s Summary of Benefits and Coverage (SBC) provision.  Requiring all health plans to provide an SBC form for each option offered by a plan is not justified because employer-sponsored plans have been providing virtually the same information in summary documents under ERISA to plan enrollees for years. Compliance with the statutory and proposed regulatory requirements will increase plan administrative costs and burdens without providing a corresponding benefit to participants and enrollees.  Thus, the Association believes that the administration should create a safe harbor that permits employers to continue using their summary plan materials so long as the materials contain the information required by the statute.