IF A GROUP EXCEEDS 100 EMPLOYEES FOR THE FIRST TIME AND HAS A FULLY INSURED PLAN, BUT DOES NOT INCLUDE DENTAL; IS A SEPARATE DENTAL SPD REQUIRED?

Here the dental plan is an employee reimbursement program which reimburses a specific amount yearly. This could easily be included as an appendix to the fully insured plan SPD. Since the claims are reimbursed, all claims are considered a post service claim. The appendix could be a 1 or 2 page addition to the fully insured plan or SPD. The appendix would state the payment provisions, covered benefits, excluded benefits, eligibility, funding and post-service claims procedure. It should be made clear that the coverage is self-funded and paid from general assets. All other information in the fully-insured SPD would be the same; including COBRA, ERISA rights, dependents, administrative Info, etc.