Distribution Options for Summary of Benefits and Coverage (SBC)

The new Summary of Benefits and Coverage (SBC) required under health care reform must be distributed to employees as part of open enrollment. Employers should consider their options for SBC distribution.

Many employers plan to distribute the SBC electronically or include a link to the SBC on the employer’s website or in the Forms library in MyEnroll.com. The following should be considered for electronic distribution of the SBC.

For individuals who are eligible for but not enrolled in coverage, the SBC may be provided electronically if:

• The format is readily accessible (such as in an html, MS Word, or pdf format);
• The SBC is provided in paper form, free of charge, upon request; and
• If the SBC is provided via an Internet posting, the plan timely advises the participants and beneficiaries that the SBC is available on the Internet and provides the Internet address. Plans may make this disclosure (sometimes referred to as the “e-card” or “postcard” requirement) by email.

For participants or beneficiaries who are already covered under the plan, the SBC may be provided electronically during the Open Enrollment period if:

• The employer provides online open enrollment. The SBC may not be provided electronically if the employer offers a paper enrollment option; and
• The SBC is provided in paper form, free of charge, upon request.

For participants or beneficiaries who are already covered under the plan, the SBC may be provided electronically during non-open enrollment periods, or if the employer offers paper enrollment, if:

• The participant has the ability to effectively access documents at a location where the participant is reasonably expected to perform duties as an employee; and
• The participant has access to the employer's electronic information system as an "integral part" of his/her job duties; or
• If the participant does not use a computer as an integral part of his or her job duties, the participant affirmatively agrees to receive the SBC electronically.

For individuals who request the SBC online, the SBC may be provided electronically.

The SBC may always be mailed to an individual’s home address, addressed to the individual and family.

HR professionals should consider the various options available for SBC distribution and comply with distribution requirements.