In situations where there are a number of benefit plans, each with their own separate plan numbers, that you wish to wrap together into a single Welfare Benefit Plan, there are typically two options. One option would be to merge all of the coverages into a single existing plan and terminate the benefit plan numbers of those being merged into the single existing plan. Or you could simply start a new plan with a new plan number and potentially terminate the existing plan numbers. According to the U.S. Department of Labor, welfare plan numbers begin with 501 and proceed consecutively (so, the second welfare plan of an employer would be 502, followed by 503, etc.), and a plan number can never be used more than once.
The employer/plan administrator should note that proper procedures for terminating its existing plan or plans (which could involve some corporate paperwork that addresses the plan numbers that have been terminated), and for filing terminal Form 5500s (if applicable), would have to be followed. Please consult knowledgeable benefits counsel or the party responsible for filing Form 5500s for individualized guidance regarding these procedures, as Wrap360 cannot offer legal advice.