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The One Thing Almost Every Benefits Dept. Gets Wrong

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Setting up employee benefits plans requires the production of a lot of plan materials.  And once these plans go live, the employer must create and maintain multiple plan documents.  This is usually where things start to go wrong.

Types of Employee Benefit Plan Documents
  • Insurance Contract or Agreement
  • Corporate Resolution (for health plan and retirement plans; authorizes establishment of the plan)
  • Summary of Benefits Coverage (SBC) (usually a two to four-page summary of basic plan features and costs)
  • Certificate of Coverage (COC) (detailed description of the plan’s benefits; usually provided by the insurer)
  • Summary Plan Description (SPD) (usually includes the COC plus the required ERISA language and special notices such as HIPAA Privacy Notice, Medicare Part D Notice of Creditable Coverage, Medicaid and CHIP, Newborn and Mother's Protection Act, Special Enrollment Rights, Women's Health Cancer Rights Act.  Is basically a summary of the plan document meant for employee consumption)
  • Plan Document - (technical document of little use to employees as it is intended to serve as a guide to the plan administrator (employer) in how to carry out the provisions of the plan)

These documents are important from both a legal and employee education perspective.  Employers are required by law to have a SPD and Plan Document for each plan.  Every employee who enrolls in a benefit plan must receive that plan's SPD within 90 days of the enrollment.  In addition, employers must administer their plans in accordance with the terms and conditions outlined in the Plan Document.  The integrity of these documents is the top priority of every employee benefits department.  NOT!
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