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. Federal instructions actually require the beginning and end dates of the coverage period, but permit the issuer to enter only a beginning date, such as ‘Beginning on or after 01/01/2025,’ when the end date is not known when the SBC is prepared. A carrier’s plan-year label is a looser variation on that allowance, and such carrier-issued SBCs are commonly used when they are 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.