This CLE webinar will provide counsel with a review of ERISA requirements for written plan documents and summary plan descriptions (SPDs). The panel will explain how plan sponsors and their counsel can create a wrap plan and SPD documents as an effective and cost-efficient means of ensuring compliance. The panel will also address summary of benefits and coverage (SBC) for group health plans.
With a variety of health benefits to offer, plan sponsors who rely on insurance company policy or contract documents alone to meet ERISA's SPD disclosures to plan participants are at risk of falling short in meeting legal requirements.
Wrap documents are a cost-effective tool for plan sponsors that can be leveraged with an SPD to ensure ERISA compliance. A single filing can incorporate by reference all group insurance policies and contracts used to provide welfare benefits while providing explicit language clarifying the sponsor's position.
The ACA-mandated SBC, a summary of plan features like covered benefits, coverage limitations and exceptions, along with the SBC template provides clarity on the DOL and HHS position on safe harbors and enforcement.
Listen as our panel of experienced ERISA practitioners examines wraps and SPDs for ERISA welfare benefit plans. The panel will give special attention to strategies for providing cost-effective documents to plan sponsors and administrators that comply with ERISA and DOL requirements while avoiding potential challenges from plan participants. The panel will also address the SBC disclosure mandated by the ACA.
- Wrap plans and SPDs
- Determining if a plan triggers ERISA disclosures to participants
- Employee welfare benefit plans under ERISA
- DOL safe harbor
- ERISA requirements
- Written plan documents
- SPDs for plan participants
- Penalties for noncompliance
- The wrap approach
- Cost efficiencies
- What to include in wrap documents
- DOL model statement of rights
- References to other documents
- Ensuring consistency of plan documents
- Summary of benefits and coverage (SBC)
- Minimum essential coverage
- Minimum value standard
- Annual limits on essential health benefits
The panel will review these and other essential questions:
- What types of employee welfare benefit plans are subject to ERISA reporting and disclosure requirements and what are the penalties for failing to comply?
- What information is included in plan wrap documents and SPDs to ensure ERISA compliance?
- What language and provisions must be disclosed to plan participants to ensure an accurate summary of a plan that will meet SPD requirements?
- What are the key distinctions between SPDs and SBCs?
Faculty: R. Brent Gambill, Shareholder, Coolidge Wall Co.
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