It can be easy to lose sight of the requirement to periodically update a pension summary plan description (SPD) because SPDs no longer need to be filed with the U.S. Department of Labor. Plan sponsors can potentially find themselves more focused on annual governmental filings such as Form 5500, Pension Benefit Guaranty Corporation (PBGC) premium, Schedule 8955-SSA, and annual participant notifications such as the annual funding notice. But don't overlook required SPD updates.

SPDs are required to be updated every five years if there have been any material plan changes since the last SPD update or every 10 years no matter what. SPDs should be carefully drafted to be consistent with the provisions of the official plan document.

Updated SPDs should be provided to all plan participants including actives, terminated deferred vested, retirees, and beneficiaries. New active participants should be provided an updated SPD within 90 days of becoming eligible to participate in the pension plan.

In the event there is a material plan change after the issuance of an updated SPD, a summary of material modification (SMM) should be provided within 210 days after the end of the plan year in which the change was adopted. An SPD updated to reflect the plan change can be provided in lieu of providing an SMM.

SPDs can be provided to plan participants either by mail, distribution at the plan sponsor's work place, or posted on the plan sponsor's employee benefits website.

Not having an updated SPD can become an issue when participants have questions about their pension benefits. Having an updated SPD facilitates responding to participant questions.

Plan sponsors should review the latest version of the pension plan SPD to see if an update is required.