The Plan Document
ERISA requires every employee benefit plan to be established and maintained pursuant to a written instrument. The plan document is the legal foundation of the plan — it defines the plan's benefits, eligibility rules, contribution requirements, claims procedures, and administrative structure. The plan document is the authoritative source for resolving disputes about plan benefits.
Watch Out
In Cigna Corp. v. Amara (2011), the Supreme Court held that the SPD is not the plan document — it is a summary of the plan document. If the SPD conflicts with the plan document, the plan document controls. This means employers must maintain both a current plan document and a current SPD, and must ensure they are consistent.
The Summary Plan Description
The SPD is a plain-language summary of the plan that must be provided to participants within 90 days of becoming covered. The SPD must include all required content, including a description of benefits, eligibility requirements, claims procedures, and participants' rights under ERISA.
| Required SPD Content | Notes |
|---|---|
| Plan name and type | Must identify the plan as a health plan |
| Employer and plan administrator information | Name, address, and EIN |
| Eligibility requirements | Who is eligible and when coverage begins |
| Description of benefits | What is covered and what is excluded |
| Claims and appeals procedures | How to file a claim and appeal a denial |
| ERISA rights statement | Required statement of participant rights under ERISA |
| HIPAA special enrollment rights | Description of special enrollment rights |
| COBRA rights | Description of COBRA continuation rights |
Wrap Documents
Many employers use a wrap document — a single plan document that wraps around multiple benefit programs (medical, dental, vision, life, disability) and incorporates them into a single ERISA plan. A wrap document simplifies plan administration by creating a single plan document and SPD for all benefits.