Thank you for partnering with us on your Wrap Plan Document and Summary Plan Description (SPD). As we enter 2026, it is important to maintain these documents to reflect regulatory changes and any material updates 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 2026:

Changes to Plan Document/SPD:

  • Clarification of HIPAA-excepted benefits in Plan Document regarding certain fertility programs.

    NOTE: This recent clarification permits employers more flexibility to offer fertility programs without the imposition of ACA market reforms.

  • Revised language in Transparency in Coverage Rule section of Plan Document and SPD to note new CMS guidance released in response to an executive order.

  • Updated HIPAA language in Plan Document and SPD to note protections for substance use disorder in legal proceedings, effective February 16, 2026.

    NOTE: An updated privacy notice will be provided to clients upon government approval.

  • Updated HIPAA language in Plan Document and SPD to remove Court-vacated language regarding protections for PHI related to reproductive healthcare.
  • Expanded Gag clause provision requirements in Plan Document to include “downstream agreements” relating to TPAs and other service providers based upon the 2025 HHS FAQs.
  • Removed 2025 requirements in Plan Document regarding DOL final 2024 rule relating to the Mental Health Parity Act.  The DOL is presently in litigation and will not be enforcing these rules.

  • Added language in Plan Document and SPD addressing preventive care services, which includes the December 20, 2025, screening and counseling provisions under the ACA.

    NOTE: Included link to full list of preventive care services.

  • Added language to Plan Document regarding optional HSA relief under the One Big Beautiful Bill Act.

  • 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

  • Updated out-of-pocket maximum for essential health benefits for 2026 in Plan Document.

Changes to Model Notice Package:

  • Updated CHIP Notice July 31, 2025

  • Updated HIPAA Notice of Privacy Practices (Upon government availability)

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 2026:

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!