self insured cafe plan - over 100 - audit required?

[Guest Betsy Oakey]

I have what I think is a wrap plan, pop and self insured

claims paid through employer general assets, using administrative services of a tpa

do we have to have an independent audit done for the self insured (well over 100 participants)

thanks

[Guest jackmo]

If you have a wrap plan you are wrapping more than one separate ERISA benefits (such as Health and Dental, or Vision and Life, etc.). Your POP plan is not an ERISA benefit so it's not wrapped in with the ERISA benefits.

It seems you're asking if you need an independent audit of the wrap plan (and not the 125 plan). The answer is "no". You may be thinking of independent audits of the 401-k, pension, etc. which are required.

Usually, pensions and 401-ks are not wrapped in with your health and welfare benefits.

[Bill Presson]

I have what I think is a wrap plan, pop and self insured

claims paid through employer general assets, using administrative services of a tpa

do we have to have an independent audit done for the self insured (well over 100 participants)

thanks

With welfare plans, generally audits are only required if the assets are held in trust.

[Guest Betsy Oakey]

My question was phrased badly and I have done MORE research.

I have a wrap plan, FSA and POP, but within this plan I also have health benefits paid for using particiant contributions for some employer self-insurance.

I know the POP does not need an audit (and I am not mixing in the 401k, this is all health benefits) but I was thinking that the self-insurance part may need an audit. After the additional research I realized that the deciding factor is how the assets are held. The document clearly says, as general assets of the employer and not plan assets. And I think Tecnical Release No. 92-01 is giving the 125 plan a free pass. I understand it to say, if plan is POP, no audit, if plan uses participant contributions, not in a trust, and even if really should be held in a trust as plan assets but are not, they will not assert a violation.

thanks for the help