"Although it is not uncommon, especially in the self-funded health plan context, for a single document to function as both an SPD and plan document, this case illustrates some of the pitfalls of that approach. The SPD in this case (though purporting, by its terms, to serve as both the SPD and plan document) fell short in satisfying ERISA's requirements for a plan document. Only by coupling the SPD with the plan's trust agreement was the Ninth Circuit able to conclude that an ERISA plan existed." [Mull v. Motion Picture Ind. Health Plan, No. 15-56246 (9th Cir. Aug. 1, 2017)]  MORE >>