David Thornton and Catherine Simpson Outline 2022 Welfare Plan Automatic Participant Disclosures

November 14, 2022
BenefitsPRO

Bass, Berry & Sims attorneys David Thornton and Catherine Simpson authored an article published by BenefitsPRO on November 11 highlighting takeaways from the firm’s “2022 Welfare Plan Automatic Participant Disclosures Checklist.”

“Many companies that sponsor ERISA welfare benefit plans are currently undergoing their open enrollment process and issuing related participant communications,” David and Catherine said. The checklist highlights certain participant disclosure requirements for use during open enrollment and throughout the plan year. These disclosures include (but are not limited to):

  • Summary Plan Description (SPD)
  • Summary Annual Report (SAR)
  • General COBRA Notice
  • HIPAA Notice of Privacy Practices
  • Notice of Creditable or Non-Creditable Prescription Drug Coverage

“Failure to comply with ERISA‚Äôs reporting and disclosure requirements may result in penalties for the employer or put the employer at a disadvantage if a dispute over an employee’s benefits arises,” the attorneys cautioned.

For a more in-depth look at those disclosure requirements, please access the full article, “2022 ERISA Welfare Plan Automatic Participant Disclosures,” which is available online.