Grandfathering Notice Requirement

A grandfathered plan must include a statement, in any plan materials provided to a participant or beneficiary describing the benefits provided under the plan, that the plan sponsor believes it is a grandfathered plan and will operate the plan accordingly. This would include, for example, plan documents, summary plan descriptions (SPDs), and annual enrollment information describing the plan’s benefits. The federal agencies have provided model language for such disclosure, although it may be modified by future guidance.

Neither American Fidelity Assurance Company nor American Fidelity Administrative Services provides tax or legal advice and, given the complexity of these laws, we always recommend working with your legal counsel on how the laws impact your specific situation.