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Before the Supreme Court issued its 2011 opinion in Cigna v. Amara, an ERISA plan’s summary plan description (SPD) was widely considered to be part of the plan’s governing documents. Plan terms found only in the SPD were enforceable just like the provisions of the group policy and certificate of insurance. In Admin. Comm. of Wal-Mart Stores, Inc. Assocs.’ Health and Welfare Plan v. Gamboa, the 8th Circuit ruled, “Where no other source of benefits exists, the summary plan description is the formal plan document, regardless of its label.”

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