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Ninth Circuit: Plan SMM Addressing ACA Changes Violated ERISA
Thomson Reuters Practical Law 
Sept. 13, 2017 "The court observed that the employer had not issued a single amended SPD or cumulative SMMs, but had issued a series of summaries (totalling 25 pages) that needed to be read in conjunction with the 2006 SPD for an individual to determine available benefits. Moreover, the court observed that the SMMs were not organized using a comprehensive table of contents[.]" [King v. Blue Cross and Blue Shield of Ill., No. 15-55880 (9th Cir. Sept. 8, 2017)] |
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