Legislative Changes 2024

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 to remain 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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The list of updates for 2024:

Changes to Plan Document/SPD:

  • 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:

      1. Eligibility Discrimination Due to Health Status
      2. 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.

    Industry News:

    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!