Short answer: Yes. SBC requirements apply to both fully insured and self-funded group health plans, although responsibility for preparing and distributing the SBC differs.
Summary of Benefits and Coverage (SBC) requirements apply broadly to group health plans, regardless of whether the plan is fully insured or self-funded. The goal is to ensure participants receive a clear, standardized summary of their coverage and costs.
For fully insured group health plans, the insurance carrier is generally responsible for preparing the SBC. The employer, as the plan sponsor, is responsible for ensuring the SBC is distributed to eligible employees and beneficiaries at the required times.
For self-funded group health plans, the employer is responsible for both preparing and distributing the SBC. Although many employers rely on third-party administrators, brokers, or legal counsel to assist with drafting the SBC using federal templates, the employer retains ultimate responsibility for compliance.
In both fully insured and self-funded arrangements, SBC requirements are intended to promote transparency and allow participants to compare health plan options using a consistent format.
Sources
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Centers for Medicare & Medicaid Services, Summary of Benefits and Coverage (SBC)
https://www.cms.gov/cciio/resources/forms-reports-and-other-resources/summary-of-benefits-and-coverage -
Affordable Care Act, Section 2715
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29 CFR §2590.715-2715
Content history
Originally published: June 16, 2025
Last reviewed: January 25, 2026