Another Grandfathered Plan Question

[Chaz]

The interim final rule on grandfathered plans has a requirement that, in order to maintain status as a grandfathered plan, a plan or insurer must include a statement in "any plan materials provided to a participant or beneficiary describing the benefits provided under the plan or health insurance coverage" that the plan believes it is a grandfathered plan. The interim final rule provides a model notice to use.

What exactly is encompassed by "any plan materials provided to a participant or beneficiary describing the benefits"? Obviously, this would include an SPD or a certificate of coverage. But what about other communications, such as an EOB, summary of benefits, open enrollment information, COBRA notices, etc.?

Do these documents have to include the statement?