Short answer: Federal guidance expects SBCs to list the specific coverage period, but some carriers issue SBCs labeled by plan year; employers typically rely on the most current version provided by the carrier.
Federal instructions for the Summary of Benefits and Coverage (SBC) state that the document should reflect the applicable coverage period so individuals can identify which version of the plan they are reviewing. This is typically shown as a specific start and end date, such as a non-calendar plan year.
Including exact dates supports transparency, particularly when employers offer multiple plans, experience mid-year changes, or operate on non-calendar renewals. Clear dates help participants distinguish between current and prior plan terms.
In practice, some fully insured carriers issue SBCs labeled more generally, such as “for plan years beginning in 2025,” rather than listing precise start and end dates. While this approach does not mirror the technical guidance, these carrier-issued SBCs are commonly used when they represent the official, current version prepared by the insurer.
Responsibility for SBC preparation differs by plan type. For fully insured plans, insurers prepare the SBC, and employers distribute it. For self-funded plans, employers are responsible for preparation and distribution. Compliance is assessed based on whether the responsible party provided the required SBC in good faith and in accordance with federal rules.
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, SBC Templates and Instructions
https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/affordable-care-act/for-employers-and-advisers/sbc-template -
29 CFR §2590.715-2715
Content history
Originally published: June 16, 2025
Last reviewed: January 25, 2026