Under Department of Labor (DOL) and Internal Revenue Service (IRS) regulations, certain information about employee benefit plans can be distributed electronically both within—and outside—the workplace.
SPDs are a problem for many employers because they often require a significant amount of time, resources and manual effort—especially if they have not been updated on a regular basis.
Because an SPD is meant to summarize—in language the average plan participant can understand—the provisions of a plan, as well as the rights and responsibilities of both the participant and the employer—the process of updating—or oftentimes creating—an SPD can be daunting. Contracts, certificates and plan documents must be reviewed, steps must be taken to confirm that the plan is actually being administered under the terms of the contract and plan document and as the employer intended—AND that the plan is in compliance with current regulations. Further, attorneys may be consulted to identify any plan provisions that might need clarification—all before content is finalized.
These challenges can be even more problematic for large, complex employers with dozens or even hundreds of SPDs. While these documents generally share common language, it is often used inconsistently because each SPD is updated individually, by different people and on different schedules. And, given the level of effort involved and the sheer numbers of SPDs to be updated, many employers are not able to provide their employees with up-to-date SPDs on a timely basis.
DirectPath’s Summary Plan Description Solution significantly reduces time and effort and ensures regulatory compliance. The solution automates the creation, maintenance and storage of SPDs, providing:
- A secure, collaborative environment supporting cooperation among internal and external stakeholders
- Built-in workflow, enabling simultaneous or sequential reviews, edits and approvals
- An audit trail of changes, maintaining version control
- A central repository for summary plan descriptions and related collateral, such as plan documents, older versions of SPDs, enrollment materials, certificates and summaries of material modification
DirectPath’s solution streamlines the annual SPD update process. For many employers, the stumbling block is the need to create or substantially update content—describing new or revised plan provisions or regulatory changes. DirectPath’s Compliance Communications team draws on decades of employee benefits communications experience to create content that is clear, concise, accurate and readable. Not sure where your documents stand? The team can provide compliance and readability analyses to identify potential risk areas within your current documentation.
And, because our technology identifies “standard” and “variable” language, content that is shared across multiple documents can be updated once and then automatically populated to all affected SPDs—ensuring consistency and eliminating the need to review the same language multiple times.
REVIEW AND DOCUMENT MANAGEMENT
The DirectPath solution operates from a central repository of historical source material, current and prior drafts and the “sections” used to create each SPD. Employers can quickly locate the documents they need, and can trace who made which edits should a question arise. Documents are stored on a “permissions” basis, so access to—and the ability to change or remove—documents can be restricted to certain groups or individuals.
The workflow mechanism allows insight at any time into where a document is in the review process, and can provide automatic reminders and status reports to the review team.
Key Benefits to Working with DirectPath:
- End-to-end solution for ERISA compliance, document creation and distribution.
- A single point of entry for plan design updates and benefit administration platform changes.
- Reduced litigation risk.
- Clear and concise documents that accurately reflect your plans.
Related Reading: SHRM: Time to Revisit the Electronic Distribution Rules for SPDs