H&W wrap plan documents

[Guest PAL100759]

Are wrap plan documents still a viable option with all of the new requirements? What are the pros and cons of using a wrap plan to cover all of your H&W plans? Thanks for your input.

PAL

[401 Chaos]

I think they are still useful documents for the purpose of filing just one Form 5500 but the varying claims procedures for health plans versus disability plans versus other welfare benefit plans means that the claims processes may be difficult or confusing to cover in a single document and single SPD. Also, one recent concern that has arisen with wrap plans is whether a Wrap Plan that is considered a hybrid entity for HIPAA Privacy purposes and has a fuly-insured medical insurance plan but self-insured health FSA opens up the fully-insured plan and/or the wrap plan document to full HIPAA Privacy Rule requirements generally applicable to the FSA. I would be interested in hearing about others' thoughts as well.

[alexa]

regardless of a wrap doc or not a sponsor with a health FSA will likely have to comply with HIPAA Privacy anyway for it's self-funded health FSA

I agree with you; the wrap allows you to file just 1 Form 5500; we are in the process of finalizing a wrap currently for our new health plan

we get around the different claims rules by refering to the individual SPD's that carriers haev drafted