Notices, Notices and More Notices: A Brief Refresher on Required Disclosures

Do you know how many disclosure requirements there are for benefit plans? If you are a plan sponsor, you probably should and then how often they have to be made. In an effort to compile everything in one list, I decided to just lay them all out as provided in the Reporting and Disclosure Guide for Employee Benefit Plans published by the DOL. Admittedly, this is their 2008 so there needs to be some updating for PPACA, but let's hit the basics. These are documents, disclosures or notices that the EBSA and the DOL anticipate are part of your benefit plan administration: All plans (retirement or welfare plans): Summary Plan description Summary of Material Modifications Summary Annual Report Plan Documents Summary of Material Reduction in Covered Services or Benefits Specific to Health Plans: Explanation of Benefits COBRA Notices Certificate of Creditable Coverage General Notice of Preexisting Condition Exclusion Individual Notice of Period of Preexisting Condition Exclusion Notice of Special Enrollment Rights Wellness Program Disclosures Women's Health and Cancer Rights Notices Medical Child Support Order Notice National Medical Support Notice Medicare Part D Notice of Creditable or Non-Creditable Coverage HIPAA Notice of Privacy Practices Notice Regarding Grandfathered Plan Status Children's Health Insurance Program Re-authorization Act Note: you should also review the EBSA's Compliance Assistance Guide: Health Benefits Coverage Under Federal Law. Whew. But what about those specific to retirement plans: Periodic Benefit Statements Statements of Accrued and Nonforfeitable Benefits Suspension of Benefits Notice Domestic Relations Order Notice Annual Funding Notices Qualified Default Investment Notice Automatic Contribution Arrangement Notice And of course, we are on the cusp of fee disclosure requirements so those have to be considered as well. Now not every plan will have every notice or disclosure as some may not be applicable to your specific plan. But as a plan sponsor, an employer should be aware of what notices and disclosures are required, and more importantly, when the notices must be distributed. Some have an annual distribution requirement, some may have more frequent distribution requirements and some might only have to be given out at the time of enrollment. My point is that a conscientious plan sponsor wants to satisfy these disclosure obligations and remain in compliance. So learn what they are, when they are due and whether they apply to your plan. And if you have questions about whether they apply to your plan, when they have to be given out or what they should contain, you can always rely on your attorney at Fox Rothschild for assistance.

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