Debb Posted April 25, 2023 Share Posted April 25, 2023 If an employer has recently bundled multiple H&W benefits under one mega wrap plan, do participants have to be supplied with all plan materials that constitute the bundled plan's SPD? Or can the plan administrator provide plan materials that describe only the benefits for which a participant is currently enrolled? For example, if the wrap plan includes M, D, and V, and an employee is only enrolled in the dental benefit, can only the dental materials (e.g., certificate/benefit summary) be supplied along with the wrap's SPD? Link to comment Share on other sites More sharing options...
Peter Gulia Posted April 26, 2023 Share Posted April 26, 2023 Even to explain one plan, the Employee Retirement Income Security Act of 1974 permits a plan’s administrator to use more than one summary plan description, making them distinct by clearly identified classes. Each SPD may omit information that cannot apply to the class of participants or beneficiaries to which that SPD is addressed. 29 C.F.R. § 2520.102-4 https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-C/part-2520/subpart-B/section-2520.102-4. But your focus on which benefit a participant enrolled in seems inapt. Rather, an SPD must describe each benefit its addressee could elect. acm_acm and Debb 2 Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com Link to comment Share on other sites More sharing options...
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