Brokers know that benefits rarely stay static. Employers add an EAP. They roll out a wellness incentive. They carve out prescription coverage to manage costs. The plan evolves, and often the documentation does not. That is where risk begins.

Medcom is expanding its employee benefits documentation support to help you close those gaps with three focused solutions: EAP SPDs, Wellness Plan SPDs, and Prescription Drug (Rx) SPDs. Each solution targets situations where employers may inadvertently trigger compliance requirements and lack the documentation to properly support the benefit.

EAP SPD: When More Than Minimal Means ERISA

Employee Assistance Programs (EAPs) may be subject to ERISA depending on their structure or funding. If the employer endorses the program, contributes toward it, or the EAP provides more than minimal benefits, an SPD may be required.

An EAP Summary Plan Description (SPD) helps:

• Define the EAP as an ERISA plan when applicable
• Clearly document eligibility, benefits, and administration
• Provide required ERISA disclosures to employees
• Reduce compliance gaps during audits or reviews

For brokers, this is an opportunity to proactively protect clients before an audit or participant inquiry.

Wellness Plan SPD: Incentives Change the Equation

Wellness programs may start simple, but can evolve into programs that trigger ERISA requirements. Incentives, ties to group health coverage, employer involvement, or the program's being referenced in benefit or compliance materials can all shift a wellness initiative into ERISA territory.

A Wellness Plan SPD helps:

• Establish the plan under ERISA when applicable
• Documents eligibility, incentives, and program rules
• Provides required ERISA rights and disclosures
• Supports consistent administration and communication

This allows you to support clients in growing their wellness initiatives while ensuring the appropriate compliance documentation is properly established.

Rx SPD: Clarity for Carved-Out Coverage

Prescription drug benefits that are carved out or separately administered often require standalone documentation. Under ERISA, these benefits must be clearly defined and communicated.

An Rx SPD helps:

• Clearly define prescription drug benefits
• Align prescription coverage with other plan documents
• Support ERISA documentation requirements
• Reduce risk of incomplete or inconsistent disclosures

For employers updating or re-establishing plan documentation, this is a critical compliance safeguard.

Why This Matters for You

These documents are not just administrative add-ons. They demonstrate proactive compliance oversight, and they help prevent small documentation oversights from becoming larger exposure issues.

If you are unsure whether a client’s EAP, wellness program, or Rx benefit requires ERISA documentation, our team can evaluate the plan and guide the next steps. You can contact us at medcomcompliance@medcombenefits.com or sales@medcombenefits.com.

New benefits create new responsibilities. With the right documentation in place, you help clients grow confidently and compliantly.