Short answer: Responsibility for SBCs depends on the plan type—insurers generally create SBCs for fully insured plans, while employers are responsible for distribution; for self-funded plans, employers are responsible for both creation and distribution.
Responsibility for creating and distributing a Summary of Benefits and Coverage (SBC) varies based on whether the health plan is fully insured or self-funded.
For fully insured group health plans, the insurance carrier is responsible for creating the SBC. The employer, as the plan sponsor, is responsible for ensuring the SBC is distributed to eligible employees and beneficiaries at required times, such as during initial eligibility, open enrollment, special enrollment events, and upon request.
For self-funded group health plans, the employer is responsible for both creating and distributing the SBC. Although employers commonly rely on third-party administrators, brokers, or benefits consultants to prepare the document, the employer remains legally responsible for compliance with SBC requirements.
While agents, brokers, and administrators may assist with preparation or timing, the compliance obligation ultimately rests with the insurer (for fully insured plans) and the employer (for distribution and for all aspects of self-funded plans).
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