Does an ERISA plan exist under Rev Ruling 61-146 ?

[Moe Howard]

Rev Ruling 61-146 says that an employer can pay the medical insurance premiums on the "individually owned medical insurance policies" of its employees. Such employer payments are not taxable (under IRC 106) to the employees..... if the employees furnish the employer with proper proof of coverage and premium $amount.

My Question:

Is such an arrangement an ERISA plan ? (Is a SPD required?)

I would think not ... because there is no group insurance policy.

[Steve72]

I think so, just based on the definition of "welfare plan" in ERISA: Any plan fund or program established or maintained by an employer to provide medical benefits.