Undocumented changes in benefits

[Guest Damien B]

I am unsure as to how to address the following scenario:

One of our self-funded health plan clients with an original plan effective date in 1988 recently restated their plan with us (we did the booklets for them).

It has just come to light that the new booklets we produced last November contain a change in the limits on psychiatric benefits (from dollar to days/visits caps).

The new booklet does not say when the change is effective, and the plan effective date as stated in the new booklet is the original plan effective date back in 1988.

A recent check of their plan logic in our claim system showed psych benefits still limited the old way, with dollar caps. Obviously this needs to be corrected to match the current plan document, as well as to comply with ERISA.

I need to set a date in the claims system for the change to be effective. Unfortunately, I can not locate any plan amendment paperwork or other documentation in our files on the change in question, and the employee who handled all this has left the company.

I do know that the work on the most recent booklet began in early 99, and this is presumably when the change was specified. This client's plan logic in our system already has revision dates of 02/1/98 and 01/01/00, which were installed to accomodate other plan changes.

Any ideas on how to remedy this mess and bring the plan and the plan document into compliance with all applicable regulation? Please help!