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A Summary of Material Modifications (or SMM) provides a summary of material changes to the plan and should be understood by the average plan participant.
Lydia is enrolled in her employer’s group health plan, which runs from January 1st, 2020 to December 31st, 2020. On March 1st, 2020 Lydia’s employer changed the location of their home office, and therefore the contact information in Lydia’s SPD is no longer correct. Since this is not considered a material reduction in covered benefits, Lydia’s employer can wait until 210 days from December 31st, 2020 (July 29th, 2020) before they send Lydia a Summary of Material Modifications. Instead of sending an SMM, Lydia’s employer could decide to send an updated SPD by the same deadline.