Wrap Documents Updated to Include New Disability Claims Procedures

Under a Department of Labor regulation that takes effect on April 1, 2018, ERISA-covered plans that provide disability benefits must comply with additional procedural requirements for disability benefit claims.

Accordingly, Wrap360 has updated its Wrap templates to include these new provisions. The changes can be found in the "Claims Procedure for Benefits Based on Determination of Disability" section of the Wrap SPD and in Article VI, Section 6.3 of the Wrap Plan Document. It is necessary to regenerate the Wrap SPD and Wrap Plan Document if you would like these changes to appear in your existing Wrap documents.

In addition, a Summary of Material Modifications (SMM) template is available on the "SMM Document" section of Wrap360.

To inform plan participants of these changes, you may either distribute the SMM or an updated copy of the Wrap SPD.

To update your existing Wraps, first update your General Plan Information to reflect that this is an "Amendment and Restatement of an Existing Plan." Then, edit the Effective Date of the Wrap Plan to reflect the date on which these revisions became effective (generally April 1, 2018). You should retain your original Plan Year in the amended Wrap SPD and Wrap Plan Document.

After saving your changes, regenerate your documents on the "Review and Generate" page. Redistribute the revised Wrap SPD to plan participants and have the revised Wrap Plan Document signed by an authorized officer of the employer.

Finally, please note that regardless of these updates, the disability claims procedures established by the disability carrier will continue to govern plan participants' disability claims, unless those procedures fail to comply with the new requirements.