As the summer comes to a close and the 4th Quarter of 2015 approaches, the end of the plan year for many benefit plans is not far away. Often, a new plan year involves plan design changes or compliance changes that should be detailed in the plan legal documents and communicated to participants. This year, potential changes that could require an updated Summary Plan Description (“SPD”) include:
- New Section 125 qualifying events for Marketplace enrollment;
- Definition of spouse following the Supreme Court’s recent ruling on same-sex marriage (Obergefell v. Hodges);
- A change to the plan year (including changes to match “early” renewals of the medical insurance plan);
- An addition or reduction to the benefits offered, or a change in plan eligibility; and
- Plan design changes, including (for 125 plans) the design of a defined contribution benefit credit or the addition of the Health FSA carryover.
For ProBenefits clients, we automatically update SPDs for any regulatory change or specific plan design change at renewal. For many of your plans, our documents were drafted broadly enough that the Marketplace qualifying events and updated definition of spouse were already included and do not require updating absent other changes. If you have any specific design changes applicable to your plan, simply note the changes on the Data Verification form you return to ProBenefits at renewal. If you have any questions about your SPD or applicable changes, contact your ProBenefits administrator.