Michigan Law

Matching the Plan Document to ABA Coverage

The plan document is the controlling text for a self-funded plan.

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The details

What to confirm in the documents

The controlling text

A self-funded plan’s plan document controls autism coverage because the state mandate does not apply.

Summary plan description

The SPD should describe ABA coverage, authorization and limits in language participants can follow.

Consistency

Compare the plan document, the SPD, the stop-loss contract and the administrator’s practice for gaps.

Update the document

If the document is silent or unclear, ask the administrator and counsel whether the plan should be clarified.

Back to the ABA guide.

Questions We Get

Matching the Plan Document to ABA Coverage: short answers

Is a benefits guide enough?

No. A benefits guide is not a plan document or an SPD.

Who should review it?

Your counsel and your administrator, with your adviser.

What if claims are being paid without a clear provision?

Ask counsel how to document the practice and whether to amend the plan.

Matching the Plan Document to ABA Coverage: not legal advice. Send us your renewal.

Sources

Where these details come from

The laws and rules named on this page link to the official text. This is general information, not legal advice, and rules change, so check the current text.

State of Michigan: Autism Legislation

29 U.S.C. 1144 (ERISA preemption)

DIFS: Autism Spectrum Disorder Health Coverage

Let’s Get to Work

Send us your renewal.

We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.

What to send

The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier

Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.

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