awnielsen

Thankfully, no. I do draft some SPDs and plan docs, but not a large volume. I see these when clients send me what I ask clients what they have been using so I have a reference. So many don't know the difference between a plan doc, an SPD, or an SBC.

I review a lot of plans where eligibility is written as "Full-time employees working 30 hours per week". To me, this raises multiple concerns: First, it doesn't account for variable hour employees of ALEs and lookback/measurement/etc. Second, and more concerning to me, is that the language is loose. If an employee hits 30 hours in one week, is that employee not then eligible? Especially if 'Full-time' is not a defined term? There has to be a better way of drafting that, right? Or am I just picking nits? Thanks in advance!

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?