Thank you for partnering with us to create your Wrap Plan Document and Summary Plan Description (SPD). As we embark into 2024, 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.
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Updated definition of Self-Funded Benefit Program in the Plan to add reference to stop-loss coverage
Removed the following sections from the Plan to streamline document:
Eligibility Discrimination Due to Health Status
Premium Discrimination Due to Health Status
Added enhanced language to Payment of Claims Upon Termination in Plan regarding statute of limitations
Based on a recent court case, enhanced language in Plan and SPD regarding exhausting claims and review procedures before proceeding with lawsuit
Enhanced language in Plan and SPD to give Plan Administrator more flexibility relating to payment where potential beneficiary’s benefits are in dispute
Removed claims language in Plan and SPD addressing standards for state review plans to streamline document
Removed No Surprises Act language due to impact of ongoing court challenges to dispute resolution provisions
Created more flexibility with respect to the extension of HIPAA privacy rights to domestic/civil union partner coverage
Updated out-of-pocket maximum on essential health benefits for 2024 in Plan
Stylistic and minor clarifying changes were made to Plan and SPD
Enhanced definition of employee in Plan and SPD in response to recent DOL pronouncement, specifically involving independent contractors/employee status
Changes to Supplemental COVID-19 Plan Amendment & SMM:
Terminated Covid-19 Plan Amendment & SMM and added language to Plan and SPD regarding FFCRA and CAA 2023.
Changes to Model Notice Package:
Updated CHIP Notice
Upcoming Changes for 2024:
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 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 2023, 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!
By Kaan Sakar|2024-01-30T13:22:51-05:00January 29, 2024|2022 News|Comments Off on Legislative changes 2024
ERISAPros, LLC is an industry-leading professional services firm located in Atlanta, Georgia specializing in developing ERISA Wrap Welfare Benefit Plans. Our system of preparing Plan Documents, SPD wrappers, and Form 5500s is based on industry best practices.