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Sample plan document for fully insured health plan?


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My suggestion is a "wrap." Develope a short supplement to the insurance company booklet. The supplement would include the employer-specific information and any other disclosures the insurer might have omitted. For example, if the Women's Health and cancer Rights explantion was no in the insurer's booklet, it could be included in a supplement.

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Does anyone have a sample plan document for a fully insured health plan that meets the requirements of an ERISA plan? I realize that many employers don't actually adopt a "plan", but rather use the insurance booklet as their plan. My understanding is that this does not meet the requiremetns of an ERISA plan. Any suggestions on where I can find a sample document to review?

DMH

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Why don't insurance companies provide all disclosures in their booklet? What if they mail them separatley to participants? I assume we wouldn't need them in the wrap plan. Is a wrap plan as simple as the minimal ERISA requirements, eligibility, rights to terminate and amend, name a fiduciary, etc.? Is all the inforamtion in the SPD booklet published by the insurance company incorporated by reference so that the wrap plan is a pretty simple document? Does anyone have a sample of this type of document?

DMH

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I think insurers don’t include all required disclosures in their certificates because the certificates are filed with the state and tailored to meet state (not federal) requirements.

I think a wrap can be as simple as a listing of the ERISA requirements. (A better communication piece is certainly possible.) The certificate and summary of benefits would be incorporated by reference.

I used to maintain a plain English checklist which a small employer could use to create its own wrap. The checklist was for employers who didn’t want to incur any legal fees to have something prepared for them. Since I work mainly with larger employers now (and prepare or review custom documents) I have not kept the list up to date. But, really, you could just use ERISA as a checklist/guide as to what additional infomration should be disclosed.

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Guest jlcowden

A wrap document is a good way to go; advantages include:

* simplicity

* ability to include numerious benefit

types eg; medical,disability, life etc.

*ability to combine numerous benefits on one 5500 form.

* ability to include by reference booklets etc.

------------------

jlcowden

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Dawn... You cant use an insurance co booklet as a plan. The booklet can be used as a SPD if it is appropriately worded and descriptive. A plan is a different issue and at the least must have a corporate resolution.

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

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Dawn:

I agree that you cannot use an insurance contract as your ERISA plan. However,if written properly, a SPD containing all ERISA requirements, including coverage exclusions and limitations, you can refer to the SPD in your "Wrap" document as containing the entire plan of benefits.

I have a SPD that has been written in this manner and I will e-mail it to you. I also have an ERISA check list that I'll e-mail. The list is fairly inclusive and includes items such as HIPAA, FMLA, Medicare Info and QMSCOs. You still might want to check with your legal council after drafting your documents to be sure that there are no other legal issues.

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