ERISA Benefit Plan Wraps and SPDs: Structuring and Amending Compliant Plan Documents and Notices
Recording of a 90-minute premium CLE webinar with Q&A
This CLE course will provide counsel with a review of ERISA requirements for written plan documents and summary plan descriptions (SPDs). The panel will explain how plan sponsors and their counsel can create a wrap plan and SPD documents as an effective and cost-efficient means of ensuring compliance. The panel will also address summary of benefits and coverage (SBC) for group health plans.
Outline
- Wrap plans and SPDs
- Determining if a plan triggers ERISA disclosures to participants
- Employee welfare benefit plans under ERISA
- DOL safe harbor
- ERISA requirements
- Written plan documents
- SPDs for plan participants
- Penalties for noncompliance
- The wrap approach
- Cost efficiencies
- What to include in wrap documents
- DOL model statement of rights
- References to other documents
- Ensuring consistency of plan documents
- Summary of benefits and coverage (SBC)
- Minimum essential coverage
- Minimum value standard
- Annual limits on essential health benefits
Benefits
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?
Faculty
R. Brent Gambill
Shareholder
Coolidge Wall Co.
Mr. Gambill has significant breadth and depth of experience to help clients achieve their benefits and executive... | Read More
Mr. Gambill has significant breadth and depth of experience to help clients achieve their benefits and executive compensation goals. He evaluates current benefit plans for improved utility; designs retirement and welfare benefit plans, nonqualified deferred compensation plans, cash and stock-based incentive programs, and other compensation and bonus programs. Mr. Gambill deals with HIPAA privacy regulations, Family Medical Leave Act, disability, military, and other leaves of absence, and drafts executive employment and severance agreements. He is accredited by the Department of Veterans Affairs to advise, counsel, and represent veterans as to claims for VA benefits.
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José M. Jara
Partner
Archer
Mr. Jara has over 20 years of ERISA and employee benefits experience, ranging from governmental compliance,... | Read More
Mr. Jara has over 20 years of ERISA and employee benefits experience, ranging from governmental compliance, fiduciary liability insurance, to the application of ERISA’s fiduciary standards and prohibited transaction provisions. Mr. Jara has extensive experience resolving issues for corporate plan sponsors and multiemployer plans before the U.S. Department of Labor, where he was formerly a senior pension law specialist and investigator.
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Emily Lucco
Attorney
Groom Law Group
Ms. Lucco advises clients on a variety of health law matters, counseling plan sponsors, insurers, and third-party... | Read More
Ms. Lucco advises clients on a variety of health law matters, counseling plan sponsors, insurers, and third-party administrators on a broad array of issues relating to ERISA, COBRA, the ACA, and the Mental Health Parity and Addiction Equity Act. She also advises clients on compliance issues related to wellness programs under HIPAA, the Americans with Disabilities Act, and the Genetic Information Nondiscrimination Act. Ms. Lucco represents employers designing health plans as well as insurers designing new products. Recently she has helped insurers conduct internal ACA audits of their business. She has also been involved in helping both employers and insurers defend government investigations.
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