When the plan is amended or when the information in the Summary Plan Description (SPD) has changed, participants should receive a Summary of Material Modifications (SMM).
Summary of Material Modifications
Description: The SMM is a plain language document that describes the plan amendment or change to the SPD.
What it should contain: The SMM would generally include changes to the following:
- name and address of the employer, plan sponsor, plan administrator, trustees;
- collective bargaining agreements;
- eligibility for participation & plan benefits;
- circumstances which may result in plan disqualification;
- circumstances which may result in denial or loss of benefits or ineligibility;
- plan year-end date; and
- benefit claim procedures and remedies available for denied claims.
Timing: The SMM must be provided no later than 210 days after the close of the plan year for which the modification was adopted. The SMM or changes in information in the SPD don’t need to be furnished separately if the changes or modifications are described in a timely SPD.
Who is responsible for sending it: The administrator of the plan.