JYo

If it is on the intranet, doesn't that mean that only certain people have access to it? Or did you mean to say it's on your internet site? I guess I'd need to know in what capacity you are required to provide the model notice (I.e., as a provider, an insurer, etc.) and to whom you need to provide it. Since there are a few different model notices for certain circumstances, this would be difficult to answer, but if you were speaking generally about the notice that certain health care providers and facilities are required to make publicly available, post on a public website, and provide to individuals, I don't know that an intranet site would be considered accessible. That is just my opinion, and is not intended to be legal advice.

Also, regardless of what the law would require, if the Participant's Plan Document or SPD states that a copy of the Plan Document will be provided upon request, then it would need to be provided. People are often so focused on what the law itself either prohibits or allows that they forget to check the language of the document(s) at issue (not that the OP did this, I'm speaking solely from experience on that).