WE ARE OR HAVE A CLIENT WHICH HAS A WRAP SPD/PLAN DOCUMENT, WHICH WAS CREATED FOR US/THEM A YEAR AGO, AND ALL OF THEIR BENEFITS AND MEDICAL COVERAGE WAS FULLY INSURED. AT THIS POINT, THEY HAVE DECIDED TO CHANGE THEIR MEDICAL TO “SELF-FUNDED” AND THE ADMINISTRATOR IS PROVIDING THEM WITH ERISA COMPLIANT SPDS. CONSIDERING WE ALREADY HAVE THE DOCUMENT COMPLETED TO INCLUDE HEALTH INSURANCE, I AM TRYING TO UNDERSTAND WHAT AMENDMENTS ARE NECESSARY WITH THE ADDITION OF THE SPD. WOULD WE NEED TO HAVE SEPARATE PLAN NUMBERS FOR THE TWO DOCUMENTS AND FILE SEPARATE 5500 FORMS?

To clarify, you would like one plan under ERISA that includes the self-funded medical, along with the fully insured benefit programs. The Administrator provided you with a SPD but not a plan Document.

In Determining what type of benefits are included in the ERISA plan, you must refer to the plan document instead of the SPD. It is possible to have multiple SPDs included within one single Plan Document. The Wrap SPD you have serves as the SPD as well as the Plan Document. Note this is along with insurance carrier certificates of coverage, booklets and policy literature. If you were to amend your existing plan and remove the fully insured medical part, while incorporating the separate SPD for the medical benefits, it would still be considered one plan for ERISA purposes.