No way. A plan is required to be a written document. What you describe is not a written document until it is reduced to writing and signed/adopted. A resolution authorizing the adoption of a plan is not the same as adopting the plan. As an aside, many years ago, I believe it was J.C. Penny that actually authorized the adoption of a cafeteria plan so that employee contributions to the health insurance premiums would be pre tax and they treated it as such. Then, it was discovered by IRS that the plan was never actually executed. As I remember, it cost them a fortune to fix it. Authorization to adopt is not the same as adopting.