You seem already to have gotten a lot of replies on the issue of whether you can use the a Web-based SPD, so I'll concentrate on the second question.
In terms of user-friendliness, I think a Web-based SPD (whether used as an adjunct to a paper SPD or on a stand-alone basis) has a lot of advantages. In most SPDs, simplifying the plan's terms enough to make the SPD user-friendly risks leaving out information that may be critical to a particular user. However, a Web-based SPD can have a simple outline, but include links to other pages for more detailed information. This keeps those people who don't need a particular piece of information from getting so bogged down in details they don't need that they get overwhelmed, while making the information available to those who do need it.
In fact, I'd go even farther--each section of the SPD could be linked to the relevant section of an online copy of the plan document itself. That would make it harder for an employee to claim that s/he had relied on the SPD, to the extent its provisions did not fully reflect the plan document.
Another thing to focus on is making navigation easy. Employees should not have to read section 4 of the SPD before getting to section 5. Rather, the initial page of the SPD should include a frame, a menu, a search engine, and/or links to ALL sections of the SPD, so that an employee can go directly to the relevant materials. For an example of what I mean, you can check out my Employee Benefits Legal Resource Site by clicking
here.
Also, make sure that any graphics you use are limited to an appropriate file size, and/or that there is a text-only version available. I've seen figures that suggest that a large percentage of people will give up on going to a site if it takes as long as 20 seconds for it to begin to load.
One final suggestion: to the extent that the SPD includes the names of the various fiduciaries of the plan, consider adding an e-mail link to each name. It is a whole lot easier for an employee to click on a link and send off an e-mail than to contact someone whose phone number or (worse yet) address is the only contact information.
[This message has been edited by CVCalhoun (edited 10-08-98).]