By: Emily Marr
The Must-Needed 3-Points to Know:
1. An ERISA attorney reviews our wraparound plan document templates prior to each new calendar year.
Every year, we perform a full legal review of our wraparound plan document templates to ensure our documents are up-to-date with current mandatory legislative changes and continue to be comprehensive compliant wraparound plan documents for our clients’ use.
2. You won’t need to worry this year if you had us prepare your clients’ plan documents for prior years.
There were no regulations implemented for 2020 that required us to amend our wraparound plan documents prepared in prior years. However, if the client makes discretionary changes such as new insurance carriers, you may need to contact us for our free or fee-based amendments.
3. Great News! We’ve made improvements to our wraparound plan document for 2020.
Although these changes will not affect plan documents prepared prior to 2020, the high-level review of our plan documents included several changes that we believe will make our plan documents even better. See below for more details.
Highlights of the Changes Made for the 2020 Plan Year:
The following changes apply to our plan documents prepared on or after the 2020 calendar year.
– Claims and Appeals Procedures. Although not required, we have updated our wraparound plan document to refer to the corresponding SPD for details on the claims and appeals procedures required under ERISA. This change eliminates any discrepancies in claims procedure requirements that may arise between the two documents. The claims and appeal procedures provisions in the SPD remain unchanged.
– HIPAA Privacy and Security Rules. The HIPAA privacy and security provisions in the plan documents have been edited to include just the provisions required by HIPAA to be in the ERISA plan documents.
– Miscellaneous Changes. Other discretionary changes, such as grammatical corrections, have been made.
Helpful Details to Know:
– What is the Wraparound Plan document and SPD?
Wraparound plan documents and summary plan descriptions (SPD) are commonly used by employers to meet the plan document and disclosure requirements of the Employee Retirement Income Security Act of 1974 (“ERISA”) as well as other federal laws. These plan documents essentially wrap federal compliance provisions around all health and welfare benefits plans provided by the employer to cover the gaps often missed by insurance carriers.
– Who is responsible for the preparation of ERISA Plan documents?
The employer as Plan Administrator (not the insurers or third-party administrators) is responsible for the preparation of the ERISA plan documents and the distribution of the ERISA required documents to plan participants.
Written by an esteemed attorney from the employee benefits broker industry, these documents have gone through DOL audits with flying colors, and are seen as standards in the health and welfare benefit industry. If you have any questions about wraparound plan documents or need a quote for a client, contact our ERISA Desk team member Aubrey Box, at email@example.com.