If you have medical, dental, vision, Employee Assistance Program, Flexible Spending Account (FSA), Health Reimbursement Arrangement (HRA), Life Insurance, Short or Long Term Disability plans, the Department of Labor may be knocking on your door asking for a Summary Plan Description (SPD) and Plan Document. They will want to know when you distributed the SPD to your employees and how. If you can't provide this information in a timely fashion you may be fined up to $110 per day.
A SPD is an outline of an employee benefit plan(s) provided under ERISA and listed above. It contains information such as the plan administrator, requirements for eligibility and participation in the plan(s), circumstances that result in disqualification or denial of benefits and identity of insurers administering the plan.
Oftentimes employers believe this is the responsibility of the insurance company but it is actually the employer who must make sure they are compliant. Medical, Dental, Vision Insurance companies will issue Certificates of Coverage which may have a great deal of the information that a SPD will have but will usually fall short of the needed language.
Typically with employers of less than 500 employees they will use a "Wrap-Around Plan" which creates a single document for all insured benefits.
If you do not have this in place, you need to get this done as the Department of Labor is starting to audit companies with more tenacity and looking for those dollars to fund the ACA . Costs can range from $200 to $1000 or more.
