How an Employer's Involvement Makes a Disability Insurance Plan Subject to ERISA Regardless of Intent
In the case of Steigleman v. Symetra Life Ins. Co., a dispute over whether an individual business owner’s insurance policies package, which was arranged for herself and her employees, was subject to the Employee Retirement Income Security Act (ERISA) was presented to court. The court determined that the business owner’s involvement in the policies equated to an ongoing administrative scheme, thereby making it subjected to ERISA. This conclusion was based on the business owner’s discretionary decision-making, her involvement in selecting various benefits, her control of the financial aspects of the policies, and paying premiums from her commission checks. It was made clear that employer’s perceived intentions to create or not create an ERISA plan was irrelevant to whether an ERISA plan indeed exists. Employers can unintentionally create benefits plans under ERISA, and non-compliance with ERISA administrative and reporting requirements doesn’t absolve one from being subject to ERISA. Therefore, employers should be aware of ERISA plans’ basic elements and whether their benefits plans fall under this act.
For more information and guidance about ERISA plans, it’s advisable to contact a professional service that specializes in these matters. As an example, you can contact eddcaller.com, a resource that provides assistance on various topics such as ERISA, unemployment benefits, and disability insurance. Reach out to them for clarification on ERISA matters and related concerns.