LUCY

Example 3 answers my questions. There are two policies. One is employer paid and one is employee paid. Both plans are carried directly by the employer and the the employer has reporting requirements. Imputed income applies for amounts over $50,000.

They are subject to ERISA.

I appreciate your input on this topic. I am all about HR compliance with 25 years experience in HR. This situation bothers me...we all work hard to understand the HR regs and laws and to see an senior HR leader simply say it doesn’t apply to this company is not right. Just confirming my understanding. Thanks for your help!

Yes

They are provided a benefits guide with high level benefit information.

Are you sure the employee purchased group term life doesn’t require imputed income? Two very large employers I worked at calculated imputed income on the life plans the employee elected to enroll in and their coverage was over $50000.

what if a company chooses not to provide SPD's?

are we required to calculate imputed income if we offer life insurance over $50,000?

If an employee requests information on a benefit plan (medical, life, vision, dental) are we required to provide an SPD for each benefit plan offered?