ERISA Benefit Plan Wraps and SPDs: Structuring and Amending Compliant Plan Documents and Notices
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.
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?
Speakers:
R. Brent Gambill, Shareholder, Coolidge Wall Co.
Jose M. Jara, Counsel, Fox Rothschild LLP
Emily Lucco, Attorney, Groom Law Group

