Tuesday February 17th 2015
New benefit plans for 2015. Check. Open enrollment. Check. Updating payroll deductions. Check. Plan for ACA compliance and reporting. Check. Updating plan documents. Che … wait, what?
In the frenzy of open enrollment and year-end, it’s easy to overlook the plan documents that make your plan legitimately exist. These plan documents are not just required at the time of origination of your plans, but must be kept up to date to reflect the way your plans exist currently. The DOL is actively auditing group health plans for compliance with ERISA (Employee Retirement Income Security Act of 1974). At the top of the lengthy list of documents that employers are asked to provide to the auditor is a copy of all current plan documents. Getting caught without current, compliant plan documents could trigger fines, penalties or even lawsuits. Let’s review the ERISA requirements for plan documents:
So, the question is – do your plan documents accurately reflect the specific details of the benefits currently offered? Have you:
If the answer is yes, then you need to review your documents and, if necessary, amend/restate your plan document and/or SPD and provide a SMM to participants and beneficiaries. Maintaining current documents not only keeps you in compliance, but could avoid those unwanted fines and penalties.
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