What constitutes a change in plan year?

[Guest LFrankel]

This may be a simple question, but I've had difficulty finding an answer for it.

Our institution established an employer-pay-all group term life insurance plan in 1963. My understanding is that a change in vendors will not constitute a change in plan year. Therefore, I am wondering what would cause a change in the plan year.

Thanks to all who respond.

[E as in ERISA]

If you amended the formal plan document changed the year...

But many insured welfare plans do not have formal plan documents. The terms are supplied by the insurance contract, the SPD, etc. (which are not necessarily complete).

The insurance contract probably does not specify the "plan year," so a change in the contract probably won't affect the plan year.

Section 102 of ERISA requires the SPD to specify the date the plan year ends. So you could check that to see if the plan year has changed.

If the arrangement is part of an omnibus plan, there may be a "wrap" document that specifies the plan year and reflects any changes.