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District Court Rules That SPD Can Be a Plan Document
Stinson Link to more items from this source
Feb. 13, 2014
"In a recent federal district court decision, the court concluded an SPD constitutes the plan document if there is no other plan document. The SPD precluded double dipping; the administrative services contract did not address the issue. The participant claimed that under Cigna v. Amara, the SPD could not be the plan document and that the plan document therefore had to be the administrative services contract. The federal district court disagreed, stating that if there is only an SPD, then the SPD is the plan document and it can be enforced." [L&W Associates Welfare Benefit Plan v. Wines, No. 12-cv-13424 (E.D. Mich. Jan. 13, 2014)]

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