The DOL Must Modernize: How Old Rules Are Hurting Benefit Plans & Participants
The ERISA Industry Committee (ERIC) today testified before the
ERIC, the only national association that advocates exclusively for large employers on health, retirement, and compensation public policies at the state, federal, and local levels, is dedicated to working with regulators and policymakers to remove unnecessary regulatory hurdles so that the resources employers set aside to provide benefits to their employees are used as efficiently and effectively as possible.
In today's testimony, ERIC focused on four areas: streamlining required disclosures; reviewing the cost impact to the plan sponsor of any proposed changes to current disclosures, with the goal of reducing cost; decreasing unnecessary, repetitive, and extraneous information in required disclosures; and promoting flexible rules on distribution and presentation to allow plan sponsors to tailor the information based on their individual workforce.
ERIC's Senior Vice President for Health Policy,
* Do not move forward with the proposal to massively expand Form 5500, especially the onerous Schedule J health plan reporting;
* End the Summary Annual Report requirement for health and wellness benefit plans;
* Move forward with DOL efforts to allow employers to put all notices online, in a centralized location where employees could access them as needed; and
* Further study the use of Summary Plan Descriptions as a reference tool for plan beneficiaries to better understand their plans.
"It is imperative that the
* Review steps to remove legal barriers attached to the Summary Plan Description (SPD) and allow employers the freedom to tailor it to their specific workforce
* Incorporate the Summary Annual Report and Summary of Material Modifications into other documents;
* Streamline the Participant Fee Disclosure information into the SPD or other documents;
* Recommend the DOL determine ways to promote electronic disclosure of materials; and
* Not include any new disclosure proposals in the Council's final report to the DOL.
"It is time that the
Click here to read ERIC's testimony (http://www.eric.org/uploads/doc/health/ERIC%20Testimony%20on%20Disclosures%20Before%20ERISA%20Advisory%20Council.pdf).
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