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Changes in reporting for guarantee issue plans under ERISA.
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Plan Information Report
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Effective immediately, The Standard has made some changes in the way it reports information that appears on the Plan Information Report (PIR) for guarantee issue (GI) cases. The PIR is a document that The Standard's GI team prepares and sends to employers who offer GI disability insurance plans with 100 or more participants during a plan year.
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The Employee Retirement Income Security Act of 1974 (ERISA) requires insurance carriers to provide information annually to allow employers or plan administrations to file Form 5500, Annual Return/Report of Employee Benefit Plan. The Standard's GI team sends the PIR to the employer or plan administrator within 120 days of the end of a plan year. The PIR will not be shared without written authorization signed by an authorized plan representative.
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The PIR includes a disclosure of all producer compensation. For reporting purposes, this producer compensation means all forms of payment to the producer relating to the placement, renewal or servicing of a particular customer's GI case including:
- Commissions.
- Overrides.
- Bonuses. (The proportional amount of bonus attributable to the particular IDI GI case.)
- Credits.
- Fees.
- Allowances.
- Recognition rewards.
- Trips or gifts from The Standard.
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Employer Communications for In force GI and Executive Benefits plans
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In tandem with making the above changes to the PIR, The Standard's GI team will send a notice to employers who have GI plans through The Standard advising of the PIR change, and providing an addendum to the original GI offer letter signed by the employer. The GI offer letter now confirms that The Standard considers the GI plan to be separate from any other disability insurance welfare benefit plan provided by the employer.
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Conditions under which PIRs are issued to employers
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The same notice will also advise employers that The Standard's GI Team will automatically prepare PIRs for employers who offer GI disability insurance plans with 100 or more covered employees at the start of a plan year.
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Upon request, The Standard's GI Team will prepare a PIR for employers, other than those referred to above, if they contact The Standard in writing at gsiprem@standard.com.
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Unless otherwise requested, the plan year for each new GI plan and all existing in force GI plans will be the initial effective date of coverage under the plan. However, The Standard's GI Team will provide employers with an Acknowledgement Form allowing them to designate a different plan year.
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Policyowner communication
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The Standard will also send an Information and Notice of Rights form to all insured GI policyowners regarding their rights under ERISA. The information and notice of rights includes:
- Confirmation that The Standard considers all policies issued under the GI plan employment benefits subject to ERISA.
- Summary Plan Description information required by ERISA. The Standard is not making any change in benefits or coverage under any GI or Executive Benefits policy. This additional documentation simply confirms compliance with ERISA.
- Instructions to policyholders to keep the SPD documentation with their original policy.
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In addition, effective March 16, 2009, the Information and Notice of Rights will be delivered with all new GI policies issued by The Standard.
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Frequently Asked Questions flyer
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Attached is an ERISA FAQ to aid you with questions that may be posed to you by brokers or GI plan administrators regarding these changes.
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Questions about GI?
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Please contact GSI@standard.com or call 800.378.6058 if you have general questions about GI IDI. We are always happy to help you.
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