Short answer: Yes. If a plan change materially affects the content of the SBC and occurs outside of renewal, an updated SBC must generally be provided at least 30 days before the change takes effect.
Although SBCs are most commonly provided during open enrollment or initial enrollment, federal rules also require updates when certain plan changes occur mid-year.
If a health plan makes a material modification that affects information included in the SBC, and the change occurs outside of the plan’s regular renewal period, an updated SBC must be distributed in advance. In most cases, the updated SBC must be provided at least 30 days before the change becomes effective.
Material modifications may include changes to covered benefits or exclusions, adjustments to deductibles, copayments, or coinsurance, or changes to provider networks that affect how coverage is accessed. The key factor is whether the change would alter information that appears in the SBC.
If a material modification is made due to circumstances beyond the plan sponsor’s control, such as a carrier-initiated change made on short notice, the updated SBC is still required but may be provided as soon as reasonably practicable after the decision is made.
These mid-year update requirements are intended to ensure employees and beneficiaries receive timely notice of significant coverage changes and can understand how those changes affect their benefits.
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 -
U.S. Department of Labor, Summary of Benefits and Coverage Final Rule
https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/affordable-care-act/for-employers-and-advisers/summary-of-benefits-and-coverage -
29 CFR §2590.715-2715
Content history
Originally published: June 16, 2025
Last reviewed: January 25, 2026