What
A compliance tracking process to confirm SBC distribution happened (and how), internally for your records and, where required, externally to your carrier or TPA as an annual attestation. The underlying legal duty to provide SBCs to participants is a separate but related obligation. See the SBC page.
Who
All employers offering group medical plans (fully-insured or self-funded with a TPA). Many carriers ask employers to certify SBC delivery each year; others handle all SBC compliance themselves. Always confirm with your carrier or broker.
When
Track at open enrollment, initial eligibility/new hire, special enrollments (within 7 business days of the enrollment request), upon participant request (within 7 business days), and 60 days before a material mid-year plan modification.
Risk
Your carrier may rely on your attestation to satisfy its own obligations; a missed attestation can create contractual issues at renewal. If underlying SBC delivery to participants was also missed, federal penalties of up to $1,443 per willful failure per participant apply (2026 rate, adjusted annually; statutory base $1,000, PHSA Section 2715(f)(3) / 42 U.S.C. 300gg-15(f)(3)).
7 days
Request turnaround
Provide an SBC within 7 business days of a participant request or special enrollment.
60 days
Material modification
A revised SBC or SMM must go out at least 60 days before a material mid-year change.
Annual
Carrier attestation
Complete any carrier attestation, typically tied to renewal, and keep a copy.
| Trigger / Event | Timing | Who Sends | Notes |
|---|---|---|---|
| Annual open enrollment | With OE materials, before enrollment deadline | Carrier/TPA or Employer | Provide an SBC for each plan option offered, not just the one the employee selects. |
| New hire / initial eligibility | With enrollment/onboarding materials; no later than 7 business days after application received | Carrier/TPA or Employer | Include in benefit packets; log delivery date and method. |
| Special enrollment | No later than 7 business days after receiving the special enrollment request | Carrier/TPA or Employer | Applies to qualifying life events. Log request date, plan options sent, and delivery method. |
| Upon request | Within 7 business days of the request | Plan/Issuer | Any participant or beneficiary may request at any time. Log request date and response date. |
| Material mid-year modification | No later than 60 days before effective date | Plan/Issuer | A revised SBC or Summary of Material Modifications must go out in advance. Document the advance delivery date. |
| Annual carrier attestation (if required) | Per carrier's deadline, typically tied to renewal | Employer / Broker | Confirm to the carrier who distributed SBCs, by what method, and when. Keep a copy of the completed attestation. |
Trigger: Annual open enrollment
Timing: With OE materials, before the deadline
Notes: Provide an SBC for each plan option offered.
Trigger: New hire / initial eligibility
Timing: No later than 7 business days after application
Notes: Include in benefit packets; log delivery date and method.
Trigger: Special enrollment
Timing: Within 7 business days of the request
Notes: Log request date, plan options sent, and delivery method.
Trigger: Upon request
Timing: Within 7 business days
Notes: Any participant or beneficiary may request at any time.
Trigger: Material mid-year modification
Timing: No later than 60 days before effective date
Notes: Revised SBC or SMM in advance; document the date.
Trigger: Annual carrier attestation (if required)
Timing: Per carrier's deadline (typically renewal)
Notes: Confirm who distributed, by what method, and when. Keep a copy.
- Current SBC PDFs for each plan option: Obtain from your carrier (fully-insured) or confirm your TPA has them ready (self-funded). Confirm you have the current version, including any language versions required for your workforce.
- Eligibility/enrollment roster: All employees (and beneficiaries at different addresses) who need an SBC, and the planned delivery method for each group.
- Distribution log template: Fields for participant name, plan option, delivery date, delivery method, and (for requests) the request date. A spreadsheet works fine.
- Carrier/TPA attestation form or portal link: Check whether your carrier requires an annual confirmation and, if so, what format and deadline they use.
1
Inventory SBCsConfirm you have the current SBC for every plan option (HMO, PPO, HDHP, etc.) before open enrollment begins. Flag any options where the SBC is missing or outdated.
2
Schedule delivery remindersSet calendar reminders for open enrollment, new hire onboarding, the 7-business-day request turnaround, and the 60-day advance window for material modifications.
3
DistributePaper (OE packets, new-hire kits) or electronic (HRIS task, email with direct link, or portal post). Always include instructions on how to request a free paper copy.
4
Log every sendRecord participant name, plan option(s), delivery date, and method. For electronic delivery, save read receipts, HRIS completion reports, or portal delivery confirmations. For mail, keep a copy of the distribution list.
5
Complete the carrier attestation (if required)Submit the carrier's annual confirmation form or portal entry: who distributed, by what method, and when. Keep a copy of the completed attestation on file.
- Electronic delivery: HRIS assignment, email with a direct SBC link, or intranet/portal post. Use clear subject lines that make the SBC easy to identify. Maintain delivery reports or read logs as your proof.
- Paper delivery: Include SBCs in OE packets and new-hire benefit kits. Keep distribution lists or signed acknowledgments.
- Free paper copy on request: Regardless of your primary delivery method, any participant may request a paper copy at no charge. Include instructions in your electronic delivery on how to make that request.
- Dependents and beneficiaries: Spouses and dependents at a different address than the participant may be entitled to a separate SBC. Keep proof of address and delivery method for those households.
- Language access: SBCs must include taglines in any non-English language spoken by 10% or more of the county population where the plan operates, directing participants to translation assistance. Confirm your carrier's SBC reflects the September 2025 CLAS tagline updates.
- Distribution logParticipant name, plan option(s), delivery date, and method for each SBC provided.
- Copies of each SBC version distributedLabeled with plan year and effective date.
- Carrier/TPA attestation confirmationsOr portal screenshots showing your submission.
- Electronic delivery confirmationsRead receipts, HRIS completion reports, or portal logs.
- Requests logDate of each participant request and date/method of your response (to show the 7-business-day turnaround).
- Material modification noticesWith documentation showing 60-day advance delivery was met.
Common traps
"The carrier handles it, so we're done." Issuers often generate SBCs, but the employer must confirm participants actually received them and keep proof. Some carriers also require your annual confirmation; missing it can create problems at renewal.
Only logging the plan the employee enrolled in: You must distribute (and log) an SBC for every plan option offered, before the election is made.
Missing the 60-day window for material modifications: Mid-year plan changes that affect SBC content require advance notice, not just a mention at next renewal.
Forgetting dependents and spouses at a different address: They may be entitled to their own SBC, and you need to document it separately.
FAQs
What is "SBC monitoring" versus "providing the SBC"?
Providing the SBC is the legal requirement to distribute the document to participants at specific trigger times. SBC monitoring is your internal tracking, and any carrier attestation, that those distributions happened correctly. This page covers the monitoring side; the underlying SBC distribution obligation is a related but separate compliance task.
Our carrier doesn't ask for an attestation. Do we still need to track?
Yes. Keep distribution logs regardless of whether your carrier requires confirmation. You need the records to respond to audits, participant requests, and any questions about whether SBCs were provided on time.
Do dependents and spouses get their own SBC?
A participant and beneficiaries at the same address can receive one copy. Beneficiaries at a different address are entitled to their own. Keep records of address and delivery method for those households.
- DOL: Summary of Benefits and Coverage, Employer Overview: DOL's main SBC page for employers, including FAQs, template links, and guidance documents.
- CMS: SBC Templates & Resources: All current SBC template files, the Uniform Glossary, and translated versions (updated September 2025).
- 29 CFR 2590.715-2715: DOL's governing regulation covering all SBC timing, format, and delivery requirements.
- 45 CFR 147.200: The parallel HHS regulation covering the same SBC requirements for health insurance issuers.
- Fully-insured vs. self-funded: For fully-insured plans, the carrier typically prepares the SBC; the employer confirms distribution and maintains records. For self-funded plans, the employer or TPA must also prepare the SBC using the HHS template; the monitoring obligation is the same but the prep work is heavier.
- Carrier attestation policies vary: Some carriers require an annual employer attestation confirming how and when SBCs were delivered; others handle all SBC compliance themselves and ask nothing of the employer. Check your carrier's administrative guide or ask your broker before each renewal cycle.
- Multiple plan options: An SBC is required for each plan option offered. If you offer three tiers, each eligible participant receives all three SBCs before making an election, and you log all three.
- State requirements: A few states reinforce SBC requirements through state insurance regulations or market conduct audits. Carriers in those states tend to be stricter about requiring employer attestations; if your carrier is asking for more documentation than usual, this may be why.