What is a summary of material modifications (SMM) and when is it required?
Last updated October 2, 2026
An SMM is the notice participants must receive when a plan changes materially between SPD updates. It's generally due within 210 days after the plan year of the change — but just 60 days for material reductions in group health coverage or benefits.
Plans change more often than SPDs get rewritten, and the SMM is ERISA's bridge. Whenever a material change occurs — benefits added or cut, eligibility modified, carrier changes affecting coverage, cost-sharing shifts — participants must be told in a document that reads like the SPD itself.
Timing has a trap in it:
- Standard changes: within 210 days after the end of the plan year in which the change was adopted.
- Material reductions in group health plan services or benefits: within 60 days of adoption.
Many employers fold SMMs into open-enrollment materials, which works if the content and timing requirements are met. The safest habit is treating every plan change as an SMM trigger and documenting the distribution — date, method, and audience.
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