Reminder: Dealers with health care plans must provide SPDs
Hereês a timely reminder for dealers with health care plans: Plan administrators must provide certain documents on the operation and management of their plan to all plan participants. One of the most important documents, the Summary Plan Description (SPD), must be made available around the time of renewal in other words, during open enrollment. The SPD tells participants what the plan is and how it operates.
In most cases, the information required in the SPD is provided by the insurance carrier, though it does not usually appear in a single source. The three sources may have different names depending on the carrier, but in general are: 1) the Evidence of Coverage or Certificate of Coverage; 2) the Group Agreement or Plan Agreement; and 3) the Summary of Benefits or Summary of Benefits and Coverage. Legal guidance on the distribution of the SPDs states that they must be furnished in a way that is reasonably calculated to ensure receipt using a method likely to result in full distribution.
The Evidence (or Certificate) of Coverage and the Group (or Plan) Agreement are documents sent out by the carrier around the time of renewal if any plan changes have occurred around the same time as the SPD.
If you have any questions about the SPD requirement, please call Ed Mullaney or Joe Koch at WANADA, (202) 237-7200. More information can also be found online at these websites:
US Department of Labor, Plan Information
US Department of Labor, Reporting & Disclosure Guide for Employee Benefit Plans
Cornell University Law School, 29 CFR 2520.104b-2 – Summary plan description.Download Bulletin PDF