With open enrollment materials, to all eligible employees.
Within 7 business days of a request, to the requester.
60 days prior to the effective date of a significant material change.
| Trigger | Due Date | Notes |
|---|---|---|
| Annual open enrollment | With open enrollment materials | Provide to all eligible employees. |
| Upon request | Within 7 business days | Provide to the requester. |
| Special enrollment | No later than first day of coverage | Provide to special enrollees. |
| Significant mid-year change | 60 days prior to effective date | If benefits or coverage change materially. |
- The SBC for each plan option (from carrier for fully-insured; from TPA/actuary for self-funded/HRAs).
- The federal Uniform Glossary of health coverage and medical terms, required to accompany or be made available with each SBC. See the Templates & Resources section below for links.
- Eligibility/distribution list (employees, dependents as applicable, COBRA, new/special enrollees).
- Proof of delivery (mail/email logs, portal post date, acknowledgments).
- Use the federal standardized format and language for SBCs.
- SBCs must be provided free of charge.
- The Uniform Glossary must accompany the SBC or be made available online; include a notice with the SBC indicating where participants can obtain it.
- Electronic delivery permitted if ERISA e-delivery rules are met; otherwise provide paper.
- Make available upon request within 7 business days.
- SBC copiesKeep SBC copies for each plan year and option.
- Format confirmationRetain carrier/TPA confirmation that the SBC meets federal format.
- Distribution evidenceLogs, portal screenshots/timestamps, and acknowledgments.
FAQs
What is a Summary of Benefits and Coverage?
The SBC outlines key plan features (covered benefits, cost-sharing, limits) in a standardized, comparable format.
When must the SBC be distributed?
During open enrollment (with enrollment materials), within seven business days upon request, to special enrollees no later than their first day of coverage, and 60 days prior to significant mid-year changes.
Are there specific formatting requirements?
Yes. The SBC must follow the federal uniform layout and plain-language rules.
Is there a companion document that must be provided with the SBC?
Yes. The federal Uniform Glossary of health coverage and medical terms must accompany the SBC or be made available online, with a notice included in the SBC indicating where participants can obtain it. See the Templates & Resources section below for direct links.
What are the consequences of failing to provide the SBC?
Willful failures to provide the SBC carry a penalty of $1,443 per affected individual (2026 rate, adjusted annually). Excise taxes may also apply.
Where can I get an SBC?
Fully-insured plans: your carrier prepares and typically provides the SBC; you generally don't need to build one yourself. Self-insured or HRA plans: work with your TPA or actuary, or start from the CMS blank template. See the Templates & Resources section below.
No state-specific variations typically apply to the federal SBC requirement.
SBC Template (self-funded and HRA plans only)
If your plan is fully-insured, your carrier builds and provides the SBC; you're done. If you are self-insured or running an HRA, you'll need to complete the SBC yourself. Start from the official CMS blank template:
Work with your TPA or actuary to populate the plan-specific fields accurately before distributing.
Uniform Glossary (all plans)
Every plan must provide the federal Uniform Glossary alongside the SBC, or make it available online with a notice of availability included in the SBC. You have a few options:
- Uniform Glossary, web version (link participants here)
- Uniform Glossary, English PDF (distribute or post on intranet)
- Uniform Glossary, Spanish PDF
The simplest approach for most employers: include the web link in your SBC cover note or OE packet so participants can access it on demand.