This SOP defines the annual production, legal review, and distribution cycle for the Summary Plan Description (SPD) and Summary of Benefits and Coverage (SBC) for all plan options offered under the Unity Care Member Plan Master Trust. It establishes responsibilities, timelines, review checkpoints, and corrective action procedures to ensure ERISA and ACA compliance.
Applies to all plan options offered to participating employer groups under the Unity Care Member Plan Master Trust. Covers SPD production, SBC production, mid-year Summary of Material Modification (SMM) notices, and all electronic and paper distribution activities.
| Role | Responsibility |
|---|---|
| TPA (Allied Benefit Systems) | Draft SPD and SBC documents based on approved plan design; incorporate Operations-directed revisions; finalize for distribution. |
| Legal Counsel (Dickinson Wright PLLC) | Review final SPD drafts for ERISA compliance, MHPAEA parity language, and trust entity accuracy. Approve before distribution. |
| Operations | Coordinate the full cycle: trigger Allied, route for legal review, run the review checklist, approve distribution, maintain the distribution log. |
| Participating Employer (Plan Administrator) | Distribute SPD/SBC to enrolled employees within required timeframes; retain proof of distribution. |
| Compliance | Monitor calendar triggers; confirm SMM requirements when mid-year plan changes occur. |
The SPD/SBC production cycle is initiated by any of the following events:
Operations contacts Allied Benefit Systems to initiate the SPD/SBC draft cycle for the upcoming plan year. Operations provides Allied with the finalized plan design, benefit summaries, cost-sharing schedules, and any changes from the prior year.
Allied drafts the SPD and SBC documents. Allied confirms that plan options, benefit tiers, and cost-sharing tables reflect approved plan design. Draft documents are delivered to Operations for review.
Operations performs a structured review of each draft document using the checklist in Section 6 below. Any deficiencies are returned to Allied with written correction instructions.
Operations routes the corrected SPD draft to Legal Counsel (Dickinson Wright PLLC) for ERISA compliance review. Legal Counsel provides written approval or revision requests within 10 business days. Operations tracks review status and follows up as needed.
Operations incorporates all Legal Counsel revisions. Final SPD and SBC are sent to Allied for formatting. Operations retains signed/email approval from Legal Counsel in the compliance file.
Operations delivers final SPD and SBC files to each participating employer with written distribution instructions. Employers must distribute to all enrolled employees no later than 90 days after the plan year start date (or within 30 days for newly eligible employees).
Operations records each distribution event in the SPD/SBC Distribution Log (see Section 9). Employers confirm distribution and return acknowledgment within 30 days of receipt.
Operations must verify each item below before routing the SPD/SBC for Legal Counsel review. Mark each item as Confirmed, Revision Needed, or N/A.
| # | Checklist Item | Verified By | Status |
|---|---|---|---|
| 1 | Trust entity name reads exactly: "Unity Care Member Plan Master Trust" (no abbreviations or alternate names) | Operations | ___________ |
| 2 | Plan Administrator identified as each participating employer (not Unity Care Solutions, LLC or Trust) | Operations | ___________ |
| 3 | DPC (Direct Primary Care) benefit described as an embedded benefit — not listed as a separate line-item or standalone plan option with its own cost-sharing schedule | Operations | ___________ |
| 4 | Pre-authorization penalty language correctly describes impact on out-of-pocket maximum (penalty does not count toward OOP max if required preauth was not obtained) | Operations / Legal Counsel | ___________ |
| 5 | Rx tiers populated with correct formulary tier descriptions and cost-sharing amounts for each plan option | Operations / Allied | ___________ |
| 6 | Plan Number 501 referenced in the plan identification section (ERISA plan number) | Operations | ___________ |
| 7 | MHPAEA mental health and substance use disorder parity language present and accurate; no benefit limits more restrictive than medical/surgical equivalents | Legal Counsel | ___________ |
| 8 | Named fiduciary, claims administrator (Allied), and appeals procedures correctly identified | Operations / Legal Counsel | ___________ |
| 9 | SBC coverage examples completed and mathematically accurate | Allied | ___________ |
| 10 | Effective date, plan year, and employer-specific information correct for each employer's version (if customized) | Operations | ___________ |
| Scenario | Deadline | Method |
|---|---|---|
| Existing enrollees — plan year start | Within 90 days of plan year start date | Electronic (with DOL safe harbor consent) or paper |
| Newly eligible employee | Within 90 days of becoming covered under the plan | Electronic or paper at enrollment |
| Upon written request | Within 30 days of request | Paper or electronic as requested |
| New employer group onboarding | Before plan effective date | Delivered by Operations to employer HR; employer distributes |
When a material change to plan terms occurs mid-plan-year, a Summary of Material Modification (SMM) must be produced and distributed.
If errors are identified in a distributed SPD or SBC:
Operations maintains a perpetual SPD/SBC Distribution Log. Each entry must include:
| Field | Description |
|---|---|
| Document Name & Version | SPD, SBC, or SMM; plan year; version number |
| Employer Group | Name of participating employer |
| Date Delivered to Employer | Date Operations sent files to employer HR |
| Distribution Method | Electronic (DOL safe harbor) or paper |
| Employee Count | Number of enrolled employees to whom distribution was made |
| Employer Confirmation Date | Date employer confirmed employee distribution complete |
| Notes | Any exceptions, corrections, or special circumstances |