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Question about Wrap Plan Document


Guest awallace8
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Assuming that your health/welfare plan SPDs are ERISA compliant, is a Plan Document required? Thanks.
maybe. The doc and spd requirements are different. If all the doc requirements are covered in your spd, then you are okay. Otherwise, no.

John Simmons

johnsimmonslaw@gmail.com

Note to Readers: For you, I'm a stranger posting on a bulletin board. Posts here should not be given the same weight as personalized advice from a professional who knows or can learn all the facts of your situation.

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Can a "summary" written in language calculated to be understood by a typical plan participant ever meet the requirements imposed on a plan document? I doubt it. I'm not even sure that requirements imposed by ERISA, COBRA HIPAA, etc. can be summarized in layman's language.

The plan document exists for several purposes:

1. To set forth the provisions of the plan in detail;

2. To be executed;

3. To enumerate and implement the legal requirements applicable to the plan;

4. To serve as a reference source to clarify issues that are not detailed in the SPD.

A reasonable length for an SPD is 10-15 pages.

A normal length for a plan document is 60-100 pages.

Finally, why is it that this question is posed over and over by lazy or cheap health practitioners? Never once has a pension person come on the Board and asked whether the SPD can be used for a plan document. The health people want the summary issued by the insurance company to be the "plan" when in fact, it doesn't even meet the DOL requirements for an SPD.

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Good points, vebaguru. The best that I've seen is where the health plan document is in the 10-15 page range, uses concrete terms to cover eligibility, benefit accruals and payments, claims process, the ERISA 'contact' info, amendment and termination process, etc., is signed, and then has schedules of what types of medical coverages apply and what do not, and have a table of annual deductibles, co-pays, and co-'insurance' obligations. Arguably, so formatted, the 10-15 pages are readable by the employees, and with the attached schedules are comprehensive in the info provided.

Nevertheless, I agree with your sentiments. Most health SPDs that are the only plan writings do not suffice the plan document requirement.

John Simmons

johnsimmonslaw@gmail.com

Note to Readers: For you, I'm a stranger posting on a bulletin board. Posts here should not be given the same weight as personalized advice from a professional who knows or can learn all the facts of your situation.

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