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Navigating Wrap Plan Documents and Summary Plan Descriptions

June 5, 2023 by Heather Gorman | Team Lead, Senior Director of Benefits Operations | Health & Welfare

Woman who is reading files in her hand.Navigating employee benefits may seem complex. However, two documents – Wrap Plan Documents and Summary Plan Descriptions (SPDs) – offer clarity and guidance. Mandated by the Employee Retirement Income Security Act (ERISA), they are vital tools for employers and employees alike.

A Quick Glance at ERISA

ERISA is a federal law that sets standards for employer-sponsored benefits, including retirement plans and healthcare coverage. It prescribes the need for plan documents and summary plan descriptions, making them a standard requirement for most employers today.

The Role of Wrap Documents & Summary Plan Descriptions

Wrap Plan Documents

A wrap plan document works like a bridge, linking the benefits plan information provided by your plan carrier with the information needed for ERISA compliance. Think of it as a cover that envelops the plan booklet, information packet, benefits summary, or insurance policy handed out by the carrier.

This cover contains key details such as:

  • Who’s managing the plan?
  • Where are the contributions coming from?
  • What’s the policy on plan amendment and termination?
  • How are responsibilities shared between the employer, insurance company, and any third-party administrators?

While your plan carrier’s documents might cover some of these points, a wrap plan document ensures every bit of necessary information is there and that ERISA’s standards are fully met.

Creating custom plan documents that meet ERISA’s requirements can be daunting and resource-heavy, particularly for smaller companies. Wrap plan documents simplify the task of collating multiple benefit plans into one unified document, a bonus for plan sponsors and administrators.

Benefits of a Wrap Document

Opting for a Wrap Document offers several advantages:

  • Simplifies ERISA compliance: Instead of dealing with piles of paperwork, a Wrap Document neatly bundles all crucial plan details.
  • Improves clarity: It presents the plan specifics in a clear and concise manner, making it easier for employees to understand their benefits.
  • Time and resource saver: Especially beneficial for small businesses, a Wrap Document eliminates the need for creating custom plan documents, saving time and resources.
  • Covers all bases: With a Wrap Document, there’s less worry about missing out on important plan details. It’s like having a safety net for your benefits plan!

Summary Plan Descriptions

Then we have the summary plan description. Designed to provide a complete summary of the plan and the benefits on offer, it’s a must-have for ERISA compliance. If a plan participant requests it, employers need to provide a free copy within 30 days. The penalty for failing to do so? A hefty fine of $110 per day.

An SPD must include all the plan’s rules and benefits, along with information from the wrap plan document. Moreover, it must contain details like:

  • Eligibility requirements
  • Contact information for the plan administrator
  • The plan year and number
  • Plan trustee information
  • Employer name, address, and tax identification number
  • The process for filing a claim
  • A declaration of the participant’s rights under ERISA

If your benefits plan features a group health plan, you’ll also need to provide information about COBRA continuation coverage and any HIPAA pre-existing condition exclusions that could apply.

Who Needs These Documents?

A man is on the phone smiling at his desk.ERISA applies to most companies, with government employers (from local to federal levels) and church plans as the primary exceptions. Beyond these two categories, any business offering health coverage must adhere to ERISA’s regulations.

ERISA governs various benefits plans, including:

  • Group health, vision, and dental plans
  • Insured disability plans
  • Prescription drug plans
  • Health flexible spending accounts
  • Certain employee assistance and wellness programs

However, health savings accounts funded by the employee, transport plans, adoption assistance programs, and other programs funded by payroll practices are not included in the wrap plan document or the summary plan description.

Who Is Responsible For Creating These Documents?

ERISA mandates that employers offering group health plans create wrap plan documents and SPDs. They need to ensure both documents are up-to-date, accurate, and offer a comprehensive understanding of employees’ benefits and rights under the plan. Non-compliance with ERISA’s requirements could lead to severe penalties.

Wrapping Up

Understanding ERISA regulations, wrap plan documents, and summary plan descriptions is vital for any employer offering group health plans. Ensuring your company’s compliance with these regulations is not just legally necessary; it’s also a step toward transparency and trust in your employee benefits package.

Navigating ERISA Compliance with eBen

Complying with ERISA regulations doesn’t have to be a daunting task. eBen is here to guide you, providing expertise in creating wrap plan documents and summary plan descriptions. For a deeper understanding of ERISA’s complex landscape and to explore how we can tailor our services to your specific needs, speak with an expert to learn more.

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