The Wrap Plan Year does not have to match the Wrap Effective Date. If this is a new plan (i.e., the plan sponsor wants to have a clean break from past practices), the plan sponsor can choose any twelve-month period for the Plan Year. The Plan Year does not have to match any insurance contract year or the open enrollment period or the employer’s fiscal year. Generally, however, most employers select a January 1 calendar year as their Plan Year, which matches the date of their open enrollment selections. If a Plan Year does match an insurance contract year and the insurance contract year changes, there is no need to change the Plan Year.
If this is an amended and restated plan (which would be the case, for example, if a plan sponsor is merging all individual coverages such as dental and life into the group health plan), the plan sponsor should generally continue to use the group health plan's existing Plan Year (which could have already been established through a prior document or practice, or in a previously filed Form 5500).
Please consult with benefits counsel for individualized guidance if you are unsure of which option applies to your plan, as Wrap360 cannot offer legal advice.