Reminders for Quarter 3

The debate is still ongoing as to whether the 3^rd Quarter is the calm before the storm. However, with renewal meetings right around the corner and marketing proposals a true whirlwind in motion, many are already in overdrive. As you keep your eye on the renewal game, be sure to be mindful of the following on the reporting and disclosure front:

1. The July 31^st deadline is two months away. There is no need to panic, as there is the option for extension to October 15^th. The extension can be e-filed, and your Plan Sponsor page in the Dashboard will note its extended status. Please notify your 5500 team if you would like to request additional time.

However, if you need the 5500 as the data source for the PCORI Fee, it does need to be e-filed by July 31^st. Please alert us immediately if this applies to you.

2. If there are plan changes to communicate to participants, don’t forget that if formatted properly, the OE material can also be the Summary Materials Modification (SMM) for your Wrap Plan Document.

Types of Plan Changes to communicate:

1. Benefit/Policy such as changes in carrier, adding or removing a benefit
2. Eligibility rule changes
3. Funding changes
4. Employer updates, such as EIN change
5. Mandatory ERISA Level changes
6. Termination of the Wrap Plan

Language to add:

If the materials include a section titled “What’s Changing for the New Plan Year,” a box at the top** of the section could be added that states:

This section constitutes a Summary of Material Modifications to the Summary Plan Description (SPD) for the Plan, thereby modifying the information previously presented in the SPD with respect to the Plan. Please keep a copy of this SMM with the SPD previously provided to you.

** ERISA material should not be listed as fine print at the bottom of the page. ERISA mandates that the Plan participants to see the SMM notice prominently.

3. Open Enrollment is also the time for Annual Notices distribution. Key notices to include are:

1. COBRA

2. HIPAA Privacy

3. HIPAA Portability

4. ACA

5. Women’s Health and Cancer Rights (WHCRA)

6. Newborns’ and Mothers Health Protection Act (NMHPA)

7. Wellness Programs

8. CAA (Surprise Medical Bills)

9. Medicare Part-D Creditable Coverage

10. Children’s Health Insurance Program (CHIPRA)

If you have any questions on the material in this blog, be sure to reach out to Ann McAdam at amcadam@wrangle550.com.