"I have a plan sponsor who received a request for plan documents for the attorney (looking for plan mis-management) on behalf of a former participant -- she was paid out in 2022 and has no account balance. Is a sponsor required to provide plan documents for the period of time the former participant was in the plan -- for example documents covering 2019-2022 plan years when they were an active participant? In my reading of ERISA and DOL regulations I only see references to 'participant' or beneficiary, which I interpret to mean an individual with an account balance."

"A potential client wants to offer health insurance for the first time. While they already have employees, most are covered by either spouses or COBRA at this time. The company wants to offer a traditional HRA for any employees who want to continue their current plans until the end of the year (so as not to incur a new accumulator with the new plan). Can an employer offer a traditional HRA selectively to these employees who choose NOT to participate in the newly offered employer-sponsored plan?"