What’s an SPD?!
Space Patrol Delta? Super Perfect Day? Special Person Driver? Spinning Pile Driver?! Summary Plan Description? Oh yeah, that’s it, at least in the context of benefit plans!So, what is a Summary Plan Description, or SPD, who needs one and why?
Plan Documents and SPDs are required for most benefit plans covered by ERISA, including Health (and “Welfare”) plans – i.e. medical, dental, vision, life, STD and LTD, etc., pre-tax plans like a Section 125 plan (typically as standalone documents), and Qualified Retirement Plans like a 401(k) or 403(b).
The Plan Document outlines all the possible parameters that could be adopted by a plan and defines and includes all the legal components. The Summary Plan Description (SPD) adopts the applicable provisions from the Plan Document, puts them in a more employee friendly, readable format, and is then distributed to each plan participant. The structure of these documents is generally similar, but the contents vary quite a bit between different benefit types and applicable laws. For example, with Health and Welfare benefits, employers often adopt a wrap SPD that pulls all medical, dental, vision, life and disability benefits under one single Plan Document and SPD. In each case, the requirements surrounding Plan Documents and SPDs are governed by ERISA through the Employee Benefits Security Administration (EBSA), a division of the Department of Labor (DOL).
With regard to pre-tax plans like a Section 105, 125 or 129, or 132 that allow pre-tax benefits for things like HRAs, employee premium contributions, Flexible Spending Accounts, Health Savings Accounts and parking and transit, Plan Documents and SPDs are required regardless of ERISA status (those IRS sections dictate these requirements, not ERISA). In other words, even if you're a governmental entity or church plan not otherwise subject to ERISA, you do need Plan Documents and SPDs for these pre-tax benefits.
This is meant as a very high level description of Plan Documents and SPDs. If you are a current client of Rose Street Advisors, please contact your Relationship Manager to discuss your needs in greater detail.
If you are not a current client of Rose Street Advisors, please feel free to contact us at 269-552-3200 or contact@rosestreetadvisors.com to speak to someone.
Ben Cohen
CEBS | EMPLOYEE BENEFITS RELATIONSHIP MANAGER
Ben Cohen, CEBS, is one of our large group Employee Benefits Relationship Managers. Following graduation from Central Michigan University (Fire Up Chips!) with a degree in Human Resources, Ben began his career in 1997 as a benefits consultant with Kushner & Company. After 18 years in that role Ben joined Rose Street Advisors in 2014. Ben’s daily focus is working with clients to offer benefit options that help recruit and retain a productive workforce in a compliant and cost-effective manner designed specifically for each employer. He also enjoys educating employees about their benefits in a fun and informative manner. Outside of work, Ben is passionate about community involvement and volunteering. He currently donates his time as a board member with the Portage Community Center, volunteers with Hospice Care of Southwest Michigan, and participates with volunteer opportunities through Rose Street Advisors’ SWEET committee. In the past, his involvement has included the American Red Cross, United Way, Volunteer Kalamazoo, Optimist Club, Jaycees, KHRMA, and the Michigan Maritime Museum. Ben loves spending time at home and at their cottage in South Haven with his wife, Jen, and their dogs. He loves travel, cars, golf, sailing, and recently started a group with friends rowing vintage wood shells (42 N’ Rowing). bcohen@rosestreetadvisors.comInterested in more?
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