Plan Documentat requirement for non-electing church organization with

[Guest TRUST53]

Does a non-electing church employer, such as a Catholic Archdiocese, need a qualified plan document if they have a matching provision for some of their employees?

or

Is it sufficient to prepare a "Statement of plan operating provisions" that also states which employee groups are eligible for the match since the church plans are not subject to ERISA?

This particular Archdiocese has a 403(B) custodial program allowing deferrals only for the schools and parishes, while it also has a 403(B) that has a match component for two high schools and the main administrative offices.