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SPDs, SBCs and Plan Documents

Summary Plan Description Requirements


The Employee Retirement Income Security Act (ERISA) requires plan administrators to give to participants and beneficiaries a Summary Plan Description (SPD) describing their rights, benefits, and responsibilities under the plan in understandable language.


New employees must receive a copy of their plan sponsor’s latest Summary Plan Description within 90 days after becoming covered by the plan. Plan sponsors are not required to file the Summary Plan Description with the Department of Labor (DOL), although they are required to provide it to DOL upon request.


Plan Document Requirements


The plan document is a comprehensive written document which describes how the plan will be operated and administered.  The plan document is typically more difficult for the member to read and understand. ERISA does not provide specific guidance on a plan document, but simply states that benefits must be administered according to a written document.


A plan document is not required to be distributed to the participants unless requested.


Summary of Benefits & Coverage Requirements


Under the Affordable Care Act (ACA) group health plans and insurers are required to provide a Summary of Benefits and Coverage (SBC) document to be produced and distributed to plan participants and benefits eligible individuals annually and at various other trigger times.


The SBC must be provided at renewal, for enrollment periods, upon request, and upon material modification. The SBC regulations also require a 60 day advance notice to be given to plan participants when a material modification to terms of the plan has been made and which affects the content of the SBC. 


The document contains a description of the benefits and coverage under a plan including cost-sharing requirements, any information regarding exceptions, reductions or limitations and common cost-sharing examples.


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This content is being provided as an informational tool. It is believed to be accurate at the time of posting and is subject to change. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this information, Meritain Health is not exercising discretionary authority or assuming a plan fiduciary role, nor is Meritain Health providing legal advice.