Thank you for partnering with us to create your Wrap Plan Document and Summary Plan Description (SPD). As we embark into 2023, it is important to keep your document up to date toremain compliant with changes in the law and any substantive changes made to your corporate structure or benefit plans.
The Plan Document and Summary Plan Description (SPD) have been modified to update, expand and clarify the language to keep compliant. In addition to these document updates, we have made formatting changes in our SPD to facilitate distribution via various web applications.
We have also updated a separate Supplemental COVID-19 Plan Amendment and Summary of Material Modification (SMM) for those regulatory and legislative changes that are expected to be more temporary in nature.
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Updated No Surprises Act Section to reflect recent court decision regarding factors to be considered during independent dispute resolution process
Clarified language in No Surprises Action Section regarding consent waiver for non-emergency services
Added Section for Transparency in Coverage rules relating to non-grandfathered and non-HIPAA-excepted group health plans
Added language to HIPAA Section regarding privacy and security compliance
Updated ERISA Rights Section to reflect recent change
Updated out-of-pocket maximum on essential health benefits for 2023
Changes to Supplemental COVID-19 Plan Amendment & SMM:
Updated provisions regarding the temporary extension of high deductible health plans providing first-dollar telehealth and other remote care services to reflect recent extension under the Continuing Appropriations Act, 2023 for plan years beginning after December 31, 2022 and before January 1, 2025
Changes to Model Notice Package:
Added the following notices for September 30, 2022:
Patient Protection Model Notice
Model Michelle’s Law Notice
Model Notice of Coverage Options (if offer health plan)
Model Notice of Coverage Options (if no health plan)
Model HIPAA Wellness Notice
Added the following notice for January 1, 2023
Transparency in Coverage Model Notice
Upcoming Changes for 2023:
We are continuing to monitor recent legislation that has either been delayed or is pending additional guidance. Once released, we will determine if any edits to our documents are required (e.g., Advanced Explanation of Benefits and the proposed rule on Section 1557 of the Affordable Care Act) and prepare and distribute any updates.
All active Wrap-Tight® accounts will have access to the Wrap Plan updates, including the updated model notice package and COVID-19 documents.
We continue our commitment to you to provide a comprehensive Wrap Plan that remains compliant with regulatory and legislative changes on an annual basis.
Please log in to your active Wrap-Tight account to generate new documents.
We take our responsibilities to you very seriously. We are always considering the impact of recent developments and trends. In our review of the DOL activities in 2022, we noted that employee complaints and investigations were up significantly. This is not an unusual trend. When the economy is anemic and job layoffs occur, employees and former employees, are much more apt to be focused on their rights and benefits. In this environment, complaints, DOL investigations and lawsuits arise more frequently. Also, Congress recently approved a huge increase in the budget to allow the hiring tens of thousands of new IRS employees. This would likely permit more audits. We are aware that the IRS and DOL do exchange information where a potential issue is discovered by either regarding their audit activities.
Having continuously updated documents and a focused team of consultants and benefit specialist during such times becomes even more important. Our documents and forward-thinking advisory staff help assure that if a complaint, audit or lawsuit occurs, you are ready to respond accordingly; thereby mitigating or possibly avoiding entirely costly penalties or litigation. This is what a superior service should do for you and your company. We are committed to providing you with this quality of service!