Non-Subscriber TX Work Comp
System
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We have a Summary Plan Description for our Employee Benefit Injury Plan that was written a few years back, as we are a Non-Subscriber in the State of Texas. In conjunction with the original Plan, which contained a Benefit Schedule, we were insured through a Private Carrier - who recommended the duration/amounts of the benefits.
Subsequently, we are no longer insured, but are contracted with a Claims Agency to process injury claims, and those claims are paid essentially off of our Facilities' 'Bottom Line'.
My question is: Is the Summary Plan Description still valid without an insurer? We certainly are conducting ourselves as if the Plan is still valid.
Sorry for throwing out such a Curve Ball? Any hitters?
Keys
Subsequently, we are no longer insured, but are contracted with a Claims Agency to process injury claims, and those claims are paid essentially off of our Facilities' 'Bottom Line'.
My question is: Is the Summary Plan Description still valid without an insurer? We certainly are conducting ourselves as if the Plan is still valid.
Sorry for throwing out such a Curve Ball? Any hitters?
Keys
Comments
If you non-subscription plan was approved for the State, I don't think it matters if you are administering it or a TPA is doing so.
To be real sure, I would contact your state DOL and see if they can tell you. You should be hopeful that the PTB investigated the propriety of this course before embarking.
Wish I could help more, but this goes far beyond my knowledge!
I would contact the "new agency" in charge of w/c and just ask them. Be careful and make sure you address them correctly. They are very picky.
E Wart