Notice of Material Plan Change

Plans Covered: As required by PPACA, participants must be provided with a notice if changes have been made to an insurance plan.  Changes can be communicated by issuing a Summary of Material Modification (SMM) or a Summary of Material Reduction in Covered Services/Benefits (SMR).  An SMM communicates general changes to plan benefits.  The SMM must be issued to all covered participants no later than 210 days following the plan year in which the change is adopted.  An SMR communicates any “material reduction in benefits or services.”  It must be sent to all covered participants within 60 days of adoption of the material reduction and, again, do not forget your COBRA participants.  There is no standard format or required language for an SMM or SMR, so a summary of changes that also conveys the value of benefits can be easily developed.