Transcript Wrap Plan Documents – The New Fundamental ACA Compliance Tool

Wrap Plan
Documents – The
New Fundamental
ACA Compliance
Tool
Reasons for an Employer to create a Wrap
Plan Document and Distribute an SPD

Required by ERISA
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Combines several benefit offerings into one plan for 5500 filing or
other purposes
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Allows employer to define elements that are often inconsistent or
missing in certificates issued by insurance carriers

Allows employer to create plan features that the carrier will not
document in insurance certificate
ACA has made them more important than ever!!
Required by ERISA
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Required by ERISA for ALL plans
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Regardless of size or funding
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But not plans that are exempt from ERISA – church and governmental
plans
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Informs participants and beneficiaries about their benefits, rights, and
obligations under the Plan
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ERISA requires that the plan documents include specific information
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Statement of Rights
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Plan Sponsor Name
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Plan funding information
Required by ERISA
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Distribution Requirements for SPD
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Within 120 days of implementing new group health plan
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Within 90 days of enrollment in plan
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Within 210 days following the last day of the 5th plan year if SMM
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Within 210 days following the last day of the 10th year if no SMM
Plan document must be provided within 30 days of a request
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Penalties
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Up to $110 per day for failure to provide
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Failure to have one does not invalidate the plan
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Bigger concern is when documents issued do not accurately reflect the
plan’s intent
Combine Several Benefit Options into
One Plan

If subject to 5500 filing requirements, will allow employer to
file only one 5500 (and will reduce penalties if filing is late or
missed)

HRA/Medical Plan or Wellness/Medical Plan – Employer will
want to have these plans combined so that you can limit
COBRA on the HRA or wellness to those who elect COBRA on
medical.
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If the plans are separate, then participants have to be given a
separate COBRA election
Create Consistent Plan Features and
Add missing ones
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Eligibility
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Medical carriers often will not customize
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ACA waiting period and eligibility details
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Leave provisions – each insurer or administrator will define based on
their own templates and preferences
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Effective date and termination of employee and dependent coverage


Usually not consistent from carrier to carrier
Plan year
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Not included in most carrier certificates
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Needed to determine compliance date for most ACA requirements
Design Plan Features
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Expand eligibility (with permission of carrier when insured or
stop loss carrier if self-funded)
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Limit eligibility
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Spousal exclusion (and/or dependent)
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Change wording to exclude those that do not comply with
eligibility audit
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Include wellness plan requirements
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Add benefits or exclusions (with permission of carrier)
ACA
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Increase in DOL Audits
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Increase in provider initiated claims appeals
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More items that need to be documented
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Waiting periods
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Eligibility
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Notices
Questions? Comments?
Polestar Benefits, Inc.
412 Jefferson Parkway, Suite 202
Lake Oswego, OR 97035
(855) 222-3358
www.polestarbenefits.com
We are happy to help!
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