2025-2026 Open Enrollment - Required Benefit Distribution Notices

Employers that sponsor group health plans should provide certain benefit notices in connection with their plans’ open enrollment periods. Some of these notices must be provided at open enrollment time, such as the summary of benefits and coverage (SBC).

Other notices, such as the Women’s Health and Cancer Rights Act (WHCRA) notice, must be distributed annually. Although these annual notices may be provided at different times throughout the year, employers often choose to include them in their open enrollment materials for administrative convenience. Some of these notices may be included in the plan’s summary plan description (SPD) or detailed benefits summary provided by a health insurance issuer or third-party administrator (TPA).

In addition, employers should review their open enrollment materials to confirm that they accurately reflect the terms and cost of coverage. In general, any plan design changes for 2025-2026 should be communicated to plan participants either through an updated SPD or a summary of material modifications (SMM).

This SSG Compliance Overview includes a chart that summarizes the benefit notices employers should provide at open enrollment time.