I have a quick question on amending a “wrap-around” plan document. I work for a TPA in Iowa, and we recently went from a full plan document that includes all plan provisions to a “wrap-around” plan document that only contains the necessary ERISA information, and refers to the SPD for all benefit, eligibility, HIPAA, COBRA, etc.

When I amend a “wrap-around” plan document, am I amending the original plan document and the SPD issued at that time, or am I amending the current SPD? I’m a little confused!

Any help will be appreciated!

Thanks!

I am glad you mentioned you are in Iowa, because the rule is different there.

Normally, when one is amending the plan, one is amending the plan document. The SPD is a summary of the plan. The SPD reacts to changes in the plan as the plan is amended. One vehicle for the reaction is a summary of material modifications (SMM), but a restated SPD may be warranted if the changes are extensive. The SPD should identify the date as of which it describes the plan and any SMM should identify the date of the change it describes.

Some folks try to have the SPD serve as the plan document. In that case, a plan amendment automatically changes the SPD as well. The change must still be published according to the SPD/SMM rules.

Thank you!