Group SPD Distribution Resources and Reminders

By now all of your cooperative’s 2019 Group Benefits Program summary plan description (SPD) and summary of material modifications (SMM) documents are available on the Employee Benefits website for you to download and distribute. The distribution deadline for these notices is March 1, 2019.

Follow these preliminary steps to make the distribution process easier:

• Download the list of 2019 SPD and SMM updates to familiarize yourself with this year’s plan changes and to help answer participants’ questions.
• Use the proposal ID to track each plan through the distribution and acknowledgement process. Each proposal you submit receives a unique proposal ID. The ID appears in the Benefit Plan Rating and Renewal feature, on your Message Center notification, on your SPDs and on the distribution acknowledgement form.
• Before you distribute your documents, review the electronic distribution rules, which describe how employee benefit plan disclosure notices can be delivered to your plan participants.
• Note who must receive the SPDs and SMMs. New employees must receive one within 90 days after the date they first become covered under the plan. Give a copy to all covered individuals by March 1: active and disabled employees; retirees; directors and retained attorneys; COBRA qualified beneficiaries; dependents of deceased employees or retirees who continue to be covered; and children covered under a qualified medical child support order.
• Finally, verify that the provisions you chose are correctly reflected in each SPD before distributing it.

Follow these steps during distribution and acknowledgement:

• Include a notice telling recipients why the disclosures are important and how they can request a free paper copy (if you are distributing them electronically). You must provide the free paper copy to anyone who wants it within 30 days of the request date, regardless of how they originally received the document.
• Acknowledge distributing older notices before processing your 2019 acknowledgements. For example, if you have unacknowledged 2018 SPDs or SMMs, clear those before proceeding to 2019.  
• Acknowledge distribution of SPDs and SMMs for all plans that are effective in 2019. 
• If you have no enrolled participants in a plan: (1) report zero as the number of recipients; (2) enter the date you’re completing the acknowledgement as the distribution date; (3) choose “Other” as the distribution method; and (4) type a message stating that no plan participants were enrolled as of the effective date.
• Keep a printed copy of the distribution acknowledgement confirmation page in your plan files.

If you have questions as you review and distribute your SPDs and SMMs, contact the group compliance team at 866.673.2299, option 7, or email us at group.compliance@nreca.coop.