Wrap Plans

[sloble@crowleyfleck.com]

I'm considering wrapping a bunch of insured (and possibly some uninsured) welfare benefits. A few questions:

When do you file the 5500 if the policies have different plan years?

Can the employer switch insurance carriers and not have to amend the wrap if its drafted generically enough?

Could we get away with wrapping the plans in 2005 and then doing DFVCP for past years as if it were one plan? (LTD and Disability were never filed)

What are the pros/cons of wrapping uninsured plans in as well? (e.g., the FSA?)

THANKS

[WDIK]

When do you file the 5500 if the policies have different plan years?

The 5500 filing is based on the plan year rather than the policy year.

[sloble@crowleyfleck.com]

THATs right--thanks for the reminder. Any other thoughts out there on the other questions?

[GBurns]

Carriers and service providers should be scheduled and incorporated by reference.

I do not know of any pros or cons, it has been more personal emotion rather than facts and circumstances. Personally I have always seen problems with wrapping FSA and self-insured items with fully insured items mainly that it becomes cumbersome documents, especially in the claims sumnission and claims appeal sections.