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Summary Plan Description

Distribution Requirements for SPDs without Medical, Dental, or Vision Benefits

This Section addresses requirements for plans not offering medical, dental, or vision benefits.

How can the SPD be delivered?

Distribution can be accomplished by personal delivery or by mail. Keep good records of distribution, including date, method, and lists of names of those receiving the SPD. There are special conditions that apply if electronic delivery is desired. See Electronic Distribution section. Contact your attorney for more information.

Included is a Sample Participant Transmittal Memo that can be used to explain what the document is and what the participant should do with it.

When are SPDs required to be distributed?

Although it is always a good idea to distribute SPDs and revisions as soon as possible, there are specific time limitations that apply.

Generally, SPDs must be distributed:

Within 120 days after the establishment of the Plan (90 days if required for medical, dental, or vision benefits discussed in Special Distribution Requirements section); and
Within 90 days after new participants begin coverage.

Revisions to SPDs generally must be distributed:

No later than 60 days after adoption of any change to a group health plan that is considered a "material reduction in covered services or covered benefits;" and
Within 210 days after the end of the plan year in which a change to the SPD is required because of a change in the Plan.

A new Summary Plan Description (form, Appendices, and booklet) generally must be distributed every five years.