plan provision by reference to another document

may a plan document reference a plan provision in it's current document by reference to a prior document?

Tentatively I say yes but a better way might be to include such provision in an appendix/addendum.

Would doing that throw the doc out of prototype or VS status?

The lawyer in me is going to come out here (my apologies, in advance), but I think doing so (with one exception) is stupid.  It's hard enough to get employers/plan administrators/recordkeepers to read a document, and making it difficult for them to see the whole thing in one place aggravates that problem.  That said, "legally" I think is permissible - but it may eliminate reliance on any determination/opinion letter issued for the document.  The one exception - and one I've used myself - is with respect to a collectively bargained plan, where the contributions are defined by what the CBA specifies - which may change from time to time independent of the plan document.

I don't know about legal but that sure sounds like a great way to end up with a VCP filing as people get confused and don't follow the document.   

I have been working for TPAs since the early '90s and there are plenty of people in the typical TPA firm that struggle to read documents much less ones that make lots of references to other sections of the document.  Now we are going to reference another document people have to keep track of and look at.  

There are just times when can we do this ought to give way to the KISS principle.  KISS= Keep It Simple Stupid.  

Agree with ESOP guy--I've been working with TPAs since the mid-70s---(started when I was 12)---and that is a recipe for VCP as was ably noted.