Thank you for partnering with us to create your Wrap Plan Document and Summary Plan Description (SPD). As we embark into 2025, 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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List of updates for 2025:

Changes to Plan Document/SPD:

  • Added reproductive healthcare as a health status in the Plan and SPD

  • Enhanced guidance in the Plan regarding fiduciary certification for the Mental Health Parity Act

  • Removed The Consolidated Appropriations Act, 2023 section from the Plan and SPD that permitted first dollar coverage of HDHP without meeting a deductible

  • Updated the Plan and SPD with optional language stating that the employer retains discretion over the use of rebates and refunds

  • Incorporated language into the Plan in accordance with the 2021 Cybersecurity Guidance, indicating the DOL’s confirmation that the rules apply to both retirement plans and health and welfare plans

  • Enhanced the General Claims Procedure section in the SPD to emphasize that participants must file a civil lawsuit within one year of exhausting the Plan’s claims procedures or forfeit the right to do so

  • Included language in the Plan and SPD that the plan sponsor attest to HHS annually by December 31 addressing the “gag clause” prohibition

  • Revised the COBRA notice period language in the SPD

  • Updated out-of-pocket maximum for essential health benefits for 2025 in Plan

  • Added language in the SPD to help participants stay informed about Medicare enrollment rules

  • Included details in the SPD relating to provider directories

  • Enhanced introductory language of the SPD to confirm that employees should not rely on verbal information

Changes to Model Notice Package:

  • Added the following updated notices for August 13, 2024:

    1. Model CHIP Notice
    2. Model Notice of Coverage Options (if no health plan)
    3. Model Notice of Coverage (if offer health plan)
    4. Model Notice Surprise Billing
    5. Model WHCRA Enrollment Notice

  • Added the following new notices for 2025:

    1. Model ICHRA Notice
    2. Model Part D Non-Creditable Coverage Disclosure Notice

  • Added the following updated notices for 2025:

    1. Model COBRA Election Notice
    2. Model COBRA General Notice
    3. USERRA Notice

Wrap-Tight® Update:

In Wrap-Tight®, a radial button was added to specify whether the plan sponsor intends to retain rebates and refunds or provide a portion of such to plan participants.

Upcoming Changes for 2025:

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.

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!