Does a welfare plan for a select group of management have to have a written plan document?

[Guest cstrong]

I understand that an insured welfare plan that provides benefits for a select group of management is exempt from ERISA's reporting and disclosure requirements (Sec. 2520.104-24), but does there have to be a written plan document as described in ERISA Sec. 402(a)(1)? Thanks in advance for any comments.

[Ron Snyder]

A written plan is required. But a policy can function as a plan depending on type type of benefit to be provided and how the policy is drafted.

Is this an insured medical plan, a life insurance plan, a disability plan or some other type of welfare plan? Each has different rules to live by. Are you concerned with ERISA only or also with deductibility and imputation of income under the Internal Revenue Code?