New SPD rules & HMO's

[alexa]

We have a self insured health plan and about 18 HMO's as well

We are in the process of rewriting our Health Benefit Plan SPD for new SPD rules

Will our HMO's be required to write SPD's now that the prior exemption forHMO's doesn't exist?

We get certificates of coverage outlining HMO contract benefits, etc...

Would this suffice as long as our main SPD included other necessary stuff like QMSCO, COBRA, etc... language?

What are others doing who are in same boat?

Thanks