I have an employer that has 2 companies that are part of a control group.
In reviewing their plan compliance (while doing something else), I saw that they had one SPD mega wrap that comprised the plans for both companies.
Thing is, the "parent" company sponsors and administers the medical and dental for both companies. The "child" company sponsored and administers some different benefits than the parent (pre-paid legal, etc.).
Correct me if I'm wrong, but shouldn't the plans for the "child" company be in a different SPD wrap (or standalone SPDs) than the "parent"'s mega wrap? I believe the code says that each administrator/plan sponsor has the requirement to furnish the SPD.
If this is just going to the "child" company's employees, I guess it is only a technical violation. Am I picking nits here?
