What types of benefits should be included in the Wrap documents?

In general, whether a benefit needs to be included in the Wrap documents depends on whether that benefit is considered an “ERISA-covered” plan. ERISA covers plans that provide “medical, surgical, or hospital care or benefits, or benefits in the event of sickness, accident, disability, death, or unemployment,” through the purchase of insurance or otherwise. All ERISA-covered plans are required to have a plan document and SPD and therefore should be included in the Wrap SPD and Wrap Plan Document.

Benefits such as employer-provided health, dental, vision, life, and most disability insurance plans should generally be included in the Wrap, as well as health flexible spending accounts (Health FSAs) and health reimbursement arrangements (HRAs).

Even if the plan is not ERISA-covered (i.e., it is exempt from ERISA’s reporting and disclosure requirements and is therefore not legally required to be included in the Wrap SPD and Wrap Plan Document), it would be a good idea to inform employees about the benefit in some manner. For that reason, non-ERISA benefits are often included in the Wrap documents by employers who choose, for administrative convenience, to communicate all benefits to which a participant may be entitled in a single document. Determining which non-ERISA benefits to include in the Wrap is ultimately at the employer’s discretion.