"[V]oluntary benefit providers systematically over-promise and under-deliver.... The carrier will not enroll all of your employees correctly.... This will increase the HR department's workload and hours will be spent on the transition.... Depending on the type of product you offer, you may have to meet minimum participation levels.... Courts regularly rule that a voluntary plan is an ERISA plan, even if the employer never intended to sponsor the plan formally.... [Yet some voluntary benefits] can be appropriate and even desirable in a handful of circumstances."

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