Wrap documents and Form 5500 data, drafted for your compliance lead to check.

Today someone on your compliance desk collects each carrier's certificate of coverage and SBC, updates the wrap for benefits added or dropped at renewal, checks the Section 125 plan against what employees pay pre-tax, and chases Schedule A statements so the employer's Form 5500 can be filed.

In the proof of concept, AI does that reading. For each group it drafts the wrap updates and the Form 5500 data sheet, lists each Schedule A it expects with what it shows, and flags what doesn't line up, such as a wrap benefit the group no longer offers. Nothing is filed, signed or sent. Your reviewer, whoever prepares these best, compares every draft with what your team produced.

A carrier's certificate of coverage describes benefits, but it is not a full ERISA summary plan description. The SPD rules also call for the plan number, type of administration, an agent for service of legal process, the plan year end, claims procedures, the ERISA rights statement and, with maternity coverage, the statement on hospital stays after childbirth. A wrap supplies those items and ties the benefits into one plan. When a renewal changes it, a summary of material modifications is due within 210 days after the plan year closes, or 60 days after adoption for a material reduction in group health benefits.

Counting decides who files. A welfare plan that is fully insured or paid from the employer's general assets need not file a Form 5500 while it has fewer than 100 participants at the beginning of the plan year. A wrapped plan counts each covered employee once across all of its benefits, so a group whose medical, dental and life plans each stayed under 100 can cross the line once they are bundled. Welfare plan numbers start at 501 and stay with a plan for good, and each benefit gets a code: 4A health other than vision or dental, 4B life, 4D dental, 4E vision, 4F temporary disability, 4H long-term disability.

Schedule A is where the carriers' numbers come in. Each insurance contract gets one, for the contract year ending with or within the plan year, so a policy renewing July 1 under a calendar-year plan reports the year ending June 30. It shows the insurer's NAIC code, persons covered at the end of the policy year, and commissions and fees paid to brokers, persistency and profitability bonuses included. Insurers owe the plan administrator this within 120 days after the plan year ends, and a self-funded plan's administrative services contract gets no Schedule A. Filed schedules are public, commissions included.

The deadlines follow the plan year. The Form 5500 is due by the last day of the seventh month after it ends, and Form 5558 adds up to two and a half months. On an insured plan the carrier writes the SBC, which must still match the design the employer chose: four double-sided pages at most in 12-point type, due 30 days before a renewing plan year, within seven business days of a request, and 60 days before any mid-year change to its content. Every SBC carries the same coverage examples: Peg having a baby, Joe managing type 2 diabetes, Mia's simple fracture. The draft reads each SBC's deductible, copays and out-of-pocket limit against the renewal decision.

The Section 125 plan is its own document. A cafeteria plan needs a written plan, and a wrap does not replace it; without one, pre-tax premiums can become taxable to employees. The draft checks that the written plan names every benefit run through payroll pre-tax and the plan year in use. Yearly notices sit around the same file, such as the Medicare Part D creditable coverage notice due before October 15 and the CMS disclosure within 60 days after the plan year starts. Your reviewer watches for quiet errors: a participant count from the wrong date, a changed plan number, a Schedule A that never came.

Once your reviewer agrees, groups whose plan years are closing go through the same job for about 30 days.

Your compliance lead approves every draft and decides what goes to the employer. The AI never signs or files a Form 5500, never sends employees a notice, and never tells an employer whether a plan must file.

Scoring stays the same in the live month: same reviewer, same written list.