Notice & DisclosureAnnual
ERISA Wrap Plan Document
ERISA §§ 402, 501; 29 CFR § 2520.102-3
Employers with multiple insured policies should maintain a wrap document that bundles all welfare benefits under a single ERISA plan. Without one, each policy is a separate plan requiring its own SPD, 5500, etc. Must be reviewed and updated at each renewal. Note for ICHRA employers: the ICHRA is subject to ERISA wrap document requirements as a group health plan.
ResponsibleClient/Other TPA (compliance TPA)
Deliver ToPlan document (internal compliance); available to participants on request
DeadlineMust exist before plan year; review/update at each renewal when plan terms change
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