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Multiple Benefits in Single Plan


Guest kredlin
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Guest kredlin

Can an employer offer health, dental, vision, STD, LTD, health FSA, dependent FSA, term life and AD&Da and transportation benefits under a single welfare plan? It would seem to me they cannot, but I can't find any guidance on this.

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Steve72

Other than on this Board I have never heard of a "wrap Plan" in this context, What is it and where can you suggest that I go look for information?

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

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Same as an "umbrella plan," if that term is more familiar to you. A single plan covers component plans. The component plans often have their own documents that are incorporated by reference. One Form 5500. Of ten, the document for the section 125 plan serves as the umbrella plan document, even if not all of the component plans are section 125 plans.

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QDROphile,

Thanks.

I read your post to mean having a "wrap plan" and filing a single Form 5500 has nothing to do with the various plans having their own documents.

******

Therefore, although you could have all the component plans under a single welfare plan, that does not remove the need for the components to have their own Plan Documents which are incorporated by reference.

There is no connection between the 5500 (single or not) and the Plan Documents.

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

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It depends. From what I've seen, that's the more common approach. However, there's nothing stopping an empolyer from using a single document to administer all of the plans. It would need to have sufficient information to operate each plan, however, and would probably be one heck of a document.

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Isn't it a requirement of the Proposed Treas Regs, for FSAs, that there must be a separate written agreement?

If so, how could you have just 1 PD?

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

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IRC 125 itself defines cafeteria plan as "a written plan." 129, though, defines DCAP as a "separate written plan of an employer." I have never been sure how these provisions relate to the single ERISA welfare plan concept, or for that matter, a single 125 plan, i.e, do you really need a separate plan and/or separate plan document. In practice, I have included the benefits in a single plan with a single document and specifying something similar to the following in the applicable article:

To the extent required by the Code, this Article shall be considered a separate written plan providing for the reimbursement of medical expenses, with the relevant other provisions of the Plan incorporated by reference.

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kredlin-

This discussion seems to have gone sideways. Consumer-driven health plans, also called defined contribution health plans, can (and do frequently) "offer health, dental, vision, STD, LTD, health FSA, dependent FSA, term life and AD&D" benefits under a "single welfare plan".

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vebaguru,

Such as whose?

George D. Burns

Cost Reduction Strategies

Burns and Associates, Inc

www.costreductionstrategies.com(under construction)

www.employeebenefitsstrategies.com(under construction)

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