Letter Sent To Each ERISA Plan Participant Did Not Constitute Valid Plan Amendment

In this case, the United States District Court held that a letter sent to each ERISA plan participant did not constitute a valid plan amendment, eliminating all health, dental, vision, and prescription drug benefits. While the letter was signed by an officer of the company, and informed the participants that the plan had been amended to eliminate medical benefits, the letter did not satisfy the written instrument requirement since it failed to enumerate the benefits which were being eliminated and failed to notify the plan participant of the specific changes to the plan documents.

Halbach v. Great-West Life & Annuity Ins. Co.

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