While Wrap Plan Documents and SPDs are required to meet ERISA compliance mandates for Plan Sponsors, many still go without them. This is partially due to staring at a blank slate, wondering what information could be needed. To give a basic outline of the details included in a Wrap Plan Document, Wrangle’s ERISA Desk has created an intake guide to reveal the foundation which coincides with the data fields of our Platform. Here are snippets of the guide for you to preview as well as the link to the full guide.
PLAN SPONSOR DETAILS
- Basic plan sponsor information – legal entity name, address, etc.
- Is the group a controlled group?
- Tax year-end date
- Entity type
- Employee Classes – enter the information for each class of employees:
- Class name – full-time, part-time, etc.
- Minimum weekly hours – required hours to be worked per week for applicable benefits
- Benefits – select all applicable benefits for the class of employees
- Waiting period – when are employees eligible for benefits?
- Termination policy – when do benefits term?
*Note that the termination policy may vary based on the line of coverage. For example, medical may term on the last day of the month following termination, and Disability may term on the date of termination. In this case, you would enter two classes indicating the benefits offered that apply to the termination policy for those lines of coverage.
- It is subject to ERISA if either of the following applies:
- Wellness program provides medical benefits such as counseling by medical professionals, shots, screenings, etc.
- Wellness program is linked to the employer’s group health plan, such as by rewarding employees for participation in the program with group plan premium discounts, premium holidays, or deductible credits.
- For a wellness program that is subject to ERISA, it falls into one or more of the following HIPAA-defined program type(s):
- Outcome-based program: Participants must attain or maintain a specific health outcome to receive the reward (e.g. not smoking, a certain BMI or cholesterol level, etc.).
- Activity-based program: Participants must perform an activity or complete an activity related to a health factor to receive the reward (e.g. walking, exercise, or diet program).
- Participatory program: The incentive/reward is based on participation only, rather than on any specific health outcomes (e.g. a free health education seminar, completion of a health risk assessment regardless of the results, a premium holiday for enrolling in a smoking cessation program regardless of whether the individual stops smoking, etc.).
- A wellness program is subject to ADA/GINA if it includes disability-related inquiries (health risk assessment questionnaire) or medical exams (health risk assessment, biometric testing, etc.).
After finding the information outlined in the guide, you took a leap towards compliance. Wrap Plan Documents and SPDs no longer hold uncertainty, as you have the foundation of your ERISA Plan.
For questions on Wrap Plan Documents and SPDs, reach out to ERISA Desk: ERISADeskinfo@ascensus.com, and for requests for the Wrap Plan Document/SPD package, reach out to Elaine Harvey, firstname.lastname@example.org.