Weekly Health Compliance Briefing

June 24, 2026

While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.

Aon Publications

 

Reminder: Deadline Upcoming for Distribution of Summary of Material Modifications for Calendar Year Plans
Plan administrators of calendar year ERISA plans must distribute a Summary of Material Modifications (SMM) to participants and beneficiaries by July 29, 2026, if the plan had a material modification or a change in the required information in the plan’s Summary Plan Description (SPD) during the prior plan year.

Plan administrators may also meet the SMM requirement by distributing an updated SPD to participants and beneficiaries by the July 29th deadline. 

As background, the required deadlines for the purpose of distributing SMMs and SPDs are:

• An SMM must be distributed no later than 210 days after the end of the plan year in which the change is adopted and must be distributed to any newly eligible participants on a prospective basis.
• SPDs must be distributed to participants within 90 days of the participant becoming covered by the plan and to beneficiaries within 90 days after first receiving benefits.
• An updated SPD must be furnished every five years if changes are made to the SPD’s information or the plan is amended. Otherwise, an updated SPD must be furnished every 10 years.
• In the event a plan is not subject to ERISA but becomes subject to ERISA at a later date, the plan has 120 days from that date to distribute the SPD to participants and beneficiaries.

Plan sponsors should ensure their SMMs and SPDs are delivered in accordance with the above deadlines.