When implementing a Disease Management program or Wellness Program, when is it necessary to include the information in the Plan Document for a self-funded plan? These are not required programs but do they follow under ERISA? Can employee communication of these programs be separate from the Plan Doc or SPD?

Which Plan Document and which SPD?

If the new programs are part of the program to which the PD and SPD (that you are referring to) pertain, then the new programs would have to be included that PD and SPD.

If the new programs are not a part of the program to which the PD and SPD (that you are referring to) pertain, then they should have their own PD and SPD. I am assuming that these new programs are being introduced outside of regular Open Enrollment. If not they should be just another item in the "blanket" SPD but have their own PD.

How else would you set the rules and parameters but with a Plan Document? How else would you communicate the new programs to the employee but with an SPD?

Isn't that the reason for a Plan Document and SPD?