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OPS-SOP-024 — Annual Compliance Renewal Cycle
(Notices, Amendments & Summary of Material Modifications)

Document IDOPS-SOP-024 Version1.0 Effective Date[TBD — upon adoption] Next ReviewAnnually OwnerCompliance / Operations
Prepared ByOperations

1. Purpose & Scope

This SOP governs the annual compliance renewal cycle for the Unity Care Member Plan Master Trust, including plan document updates, Summary Plan Description (SPD) revisions, Summary of Benefits and Coverage (SBC) updates, Summary of Material Modifications (SMMs), and formal plan amendments. It applies to all employer groups participating in the Trust and covers activities occurring at the start of each plan year and any time a material plan change occurs mid-year.

Entities covered: Unity Care Solutions, LLC; Unity Care Member Plan Master Trust; Unity Care Solutions – TN, LLC (captive); all participating employer Plan Administrators.

2. Definitions

TermDefinition
SMMSummary of Material Modification — a written notice to participants describing a material change to plan benefits, cost-sharing, or eligibility rules. Required within 60 days of the change under ERISA § 104(b)(1).
SPDSummary Plan Description — the primary disclosure document given to plan participants describing benefits, rights, and obligations.
SBCSummary of Benefits and Coverage — standardized four-page disclosure required under ACA; distributed at open enrollment and upon request.
Plan AmendmentA formal legal modification to the plan document, signed by each employer's Plan Administrator and filed with the Trust.
Material ChangeAny change that would affect a participant's benefits, cost, eligibility, or rights under the plan in a way a reasonable participant would consider significant.
Plan AdministratorThe designated employer representative with authority to sign plan amendments and fiduciary decisions for that employer group.

3. SMM Trigger & Timeline

ERISA Requirement: An SMM must be distributed to all affected participants within 60 days of a material plan change taking effect. Failure to timely distribute an SMM may constitute a fiduciary breach.

What triggers an SMM:

EventDeadlineResponsible Party
Material change identifiedDay 0Leadership / Operations
Legal Counsel drafts SMMWithin 14 daysLegal Counsel (Dickinson Wright)
Operations reviews & approves SMM draftWithin 21 daysOperations Director
SMM distributed to all affected participantsWithin 60 days of changeOperations (via Allied / employer HR)
Distribution confirmation log updatedWithin 5 business days of distributionOperations

4. Annual Renewal Cycle

The annual compliance renewal process begins no later than 90 days before the plan year renewal date. Steps must be completed in sequence:

Step 1Plan Design Review with Leadership
Operations convenes a review meeting with Leadership to assess proposed plan design changes for the upcoming plan year. Changes are documented in writing and shared with Legal Counsel for impact assessment. ERISA fiduciary review by ERISA Counsel (ERISA Group) is requested if design changes affect fiduciary obligations.
Step 2Legal Counsel Updates Plan Document
Dickinson Wright PLLC drafts or amends the plan document to reflect approved design changes. Operations provides a written change summary to counsel. Legal Counsel returns a redlined plan document for review within the agreed turnaround window.
Step 3Operations Updates SPD and SBC
Operations (in coordination with Legal Counsel) updates the SPD and SBC to reflect the new plan year's benefits and cost-sharing. SBC must use the standard HHS template and be finalized before open enrollment begins. SPD must be updated and distributed within 210 days after the close of the plan year in which the change was made (or sooner if SMM triggers apply).
Step 4Allied Updates Systems
Operations provides Allied Benefit Systems with the final plan design summary and effective date. Allied confirms system updates are in place before the renewal effective date. Operations verifies accuracy via test claim or benefit verification check.
Step 5Employee Notices Distributed
Operations coordinates with each employer's HR team to distribute open enrollment materials, updated SBC, and any SMMs. Distribution method is documented (email, portal, paper). A distribution confirmation log entry is created for each employer group (see Section 5).
Step 6Post-Renewal Confirmation
Operations confirms: (a) plan document is executed, (b) Allied systems reflect new plan design, (c) SBC/SPD distributed, (d) all SMMs sent within 60-day window, (e) amendment filed with Trust (see Section 6). Close-out checklist filed in version control.

5. Distribution Confirmation Log

Operations maintains a Distribution Confirmation Log for every required notice. The log must include:

FieldDescription
Employer Group NameLegal name of the participating employer
Document TypeSMM / SPD / SBC / Open Enrollment Notice
Distribution DateDate materials were sent to participants
Distribution MethodEmail / Employer HR portal / Paper mail
Number of ParticipantsCount of covered employees/members notified
Confirmation Received FromEmployer HR contact or Allied confirmation
Filed ByOperations team member completing the log entry

The log is stored in the operations compliance folder in version-controlled storage and retained for a minimum of 6 years per ERISA record retention requirements.

6. Plan Amendment Process

Legal Requirement: Every material change to the plan must be memorialized in a formal plan amendment. An amendment that is not properly signed and filed is not legally effective and may create fiduciary liability.
Step 1Amendment Drafted by Legal Counsel
Dickinson Wright PLLC drafts the formal plan amendment language based on the approved plan design change. The amendment specifies the effective date, the provision(s) being modified, and the new language.
Step 2Employer Plan Administrator Signature
Each participating employer's designated Plan Administrator must sign the amendment. Operations tracks signature status for each employer group. No employer may implement a plan change without an executed amendment.
Step 3Filed with Trust
The executed amendment is filed with the Unity Care Member Plan Master Trust records. Operations maintains a master amendment file with all amendments in chronological order, indexed by employer and effective date.
Step 4Effective Date Confirmed
Operations confirms the amendment's effective date aligns with the date communicated to participants and loaded in Allied's system. Any discrepancy is flagged to Legal Counsel immediately.
Step 5Version Control Update (GitHub Playbook)
Operations commits the executed amendment and updated plan document version to the Unity Care GitHub playbook repository. Commit message format: "Amendment [YYYY-###]: [Brief description] — Effective [DATE]". All prior versions are retained in version history.

7. Version Control & Document Retention

All plan documents, amendments, SPDs, SBCs, and SMMs are tracked in the Unity Care GitHub playbook repository under the /compliance/plan-documents/ directory. Naming convention:

Retention period: Minimum 6 years for ERISA plan records; indefinitely for executed plan documents and amendments.

8. Roles & Responsibilities

RoleResponsibilities in This SOP
Operations DirectorOwns this process; coordinates all renewal activities; approves SMM drafts; maintains distribution log; updates version control
Legal Counsel (Dickinson Wright)Drafts SMMs, plan amendments, and updated plan documents; provides ERISA compliance guidance
ERISA Fiduciary Counsel (ERISA Group)Reviews fiduciary implications of plan design changes; advises on ERISA obligations
Allied Benefit SystemsImplements plan design changes in TPA systems; confirms effective date accuracy
Employer Plan AdministratorSigns formal plan amendments; coordinates participant notice distribution with employer HR
LeadershipApproves plan design changes; participates in annual plan design review

9. Annual Compliance Calendar

TimeframeActivityOwner
90 days pre-renewalPlan design review meeting with LeadershipOperations Director
75 days pre-renewalLegal Counsel begins plan document updateLegal Counsel
60 days pre-renewalSPD/SBC drafts completed; open enrollment materials preparedOperations
45 days pre-renewalAllied system update confirmed; test verification completedOperations + Allied
30 days pre-renewalOpen enrollment materials distributed to employer HR teamsOperations
Plan year effective dateAll amendments executed and filed; distribution log completeOperations Director
Within 60 days of any mid-year material changeSMM distributed to all affected participantsOperations
Annually (post-renewal)Version control updated; compliance checklist filedOperations
OPS-SOP-024 v1.0 | Annual Compliance Renewal Cycle (Notices, Amendments & SMMs) | Unity Care Solutions, LLC — Internal / Confidential ⚑ Flag an Issue