We recently posted about an article that Patrica Moran did on The Health and Welfare Wrap Document. Meghan Burke of Mintz Levin posted the following post to reiterate some points that are relevant to educational institutions:
Recently, our colleague Patricia Moran contributed an article to Employment Matters, Mintz Levin’s Employment, Labor & Benefits blog, regarding “The Health and Welfare ‘Wrap’ Document: What It Is and Why You Want One”. In pointing out that the Affordable Care Act has altered the health and welfare regulatory landscape, Patricia recommends that employers use a “wrap” document to satisfy the Employee Retirement Income Security Act (ERISA) Summary Plan Description (SPD) and other disclosure requirements. While delving into the document’s specifics, the article brings out several of the following points that are relevant to educational institutions:
- Educational institutions have very unique employee classes and often offer different benefits to each class. A wrap document is a great way to clearly explain which employees are eligible for which benefits.
- Employers should expect increased attention from regulators now that most employer-related features of the Affordable Care Act have taken effect. Because the Affordable Care Act’s employer mandate contains several rules specific to educational institutions (such as rules addressing crediting hours to adjunct professors), these institutions could be specifically targeted for audits. Now is a good time to review benefits documents and employee communications for legal compliance.