Can I combine multiple notices into one distribution?
Yes.
The Department of Labor’s (DOL) best practices regarding participant communication and distribution of notices outlines the plan sponsor’s responsibility to send and verify all required plan notices. However, the DOL best practice details don’t clarify whether you are required to send the notices independently and get independent verification. Historically, they have allowed plans to find reasonable solutions to control plan management costs. Therefore, combining notices should be acceptable until/unless further guidance is forthcoming.
Even though combining notices may be reasonable, the plan sponsor should continue to comply with regulations regarding notice distribution, including:
- Distributing notices to all eligible and participating individuals
- Verifying receipt of these notices
- Maintaining documented logs to prove the execution of this noticing policy
- Educating concerned parties about the notices that are distributed
If you combine your notices, disseminating information detailing what is included in them is a necessary step to prove you intended to increase efficiency rather than make the noticing information more confusing. Adding simple summaries of each notice contained in the combined packet helps plan participants understand the breadth of information they receive. Additionally, if the plan’s financial advisor conducts general meetings to provide further details and answer specific questions regarding these notices, the participants will be more likely to understand their received notice(s).
In short, combining multiple notices meets compliance requirements, but don’t forget to support the participants’ educational needs if you decide to distribute multiple notices at one time.
Plan Notice can support you in this process. Our proprietary technology distributes all required notices and verifies that each participant receives them. Plan Notice combines multiple notices when appropriate and can offer a cover page to summarize the included information. If you engage our services, we accept full responsibility for any cost or fines incurred in case of improper notice, so you can have the peace of mind that comes with knowing you’re compliant.
