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Phone: 1-304-243-8152


Benefits: Electronic Distribution of Benefits Information


SECTION: HR - Benefits NEXT REVIEW DATE: August 2017
APPROVED: December 2014 REVIEWER: Director of Human Resources
APPROVED BY: Donald B. Kaminski REVISION DATE: December 2016
  REVISION NUMBER: 2

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1.0 PURPOSE

To develop procedures that are reasonably calculated to ensure actual receipt by all plan participants both within the University and those outside who are mandated to receive such information.

2.0 POLICY

2.1 Policy Statement

2.1.1 This procedure is designed to provide required disclosures to plan participants.

2.1.2 All plan participants whose job provides daily access to a computer at their work station on University grounds, for whom the University's electronic information / email system is an integral part of the plan participants' job duties and where the University can reasonably expect the plan participant to perform a portion of his / her daily duties, will receive required disclosures electronically.

2.1.3 Plan participants whose job does not entail regular, daily, use of the electronic information / email system as a routine part of their job duties and who do not have a reasonable expectation of daily access to the University system on a University computer may elect to receive required disclosures in hard-copy.

2.1.4 Plan participants whose email was returned as "undelivered" will receive required disclosures in hard- copy.

2.1.5 Plan participants outside the University will receive required disclosures in hard-copy via US Postal service unless they consent in writing to receive them via email.

2.1.6 A file of each set of disclosures will be maintained with the date of the original email, a copy of the attachments, a copy of the list of individuals to whom the required disclosures were sent.

2.2 Definitions

2.2.1 Plan Participants - Employees, beneficiaries, and others entitled to receive information.

2.2.2 Required Disclosures - Summary Plan disclosures and other related general ERISA participant disclosures.

2.2.3 Electronic Delivery - Required disclosures delivered as attachments to emails.

2.2.4 Hard-Copy - Required disclosures delivered in paper form through the mail or in person.

2.2.5 Documented Delivery - Lists of the email delivery, receipts of Certified Mail, or signed acknowledgements.

2.2.6 Email - University electronic mail delivery system.

2.3 Delivery of Required Disclosures Electronically

2.3.1 Human Resources will provide required disclosures through electronic delivery via the University email system. This ensures that all employees entered on the list serve (email) receive the information. A copy of the sent email will be saved.

2.3.2 The electronic delivery must identify the email as benefits information by providing the following:

  • A consistent message: The Subject Line of the email will state in both capitals and bold HEALTH & WELFARE BENEFITS INFORMATION.
  • Communication of significance: The first line in the body of the email will state in bold "SIGNIFICANCE" and then state why the attachment is significant. Example: "SIGNIFICANCE: The attached documents provide information on your (name the plan and what is included)".
  • Hard-Copy alternative: The final sentence in the body will state, in bold, "Plan participants have the right to obtain a paper version of these documents. Please forward your request to Human Resources via email or personal visit and a hard-copy (paper) will be provided."

2.4 Delivery of Required Disclosures in Hard-Copy

2.4.1 The University recognizes that not all employees have regular access to a University computer and their job description does not require regular use of a University computer or email. A list of all employees, their position titles, the date on which a hard-copy of the required disclosure was delivered and a signature acknowledging receipt, will be maintained.

2.4.2 An employee to whom delivery of the required disclosures was made electronically and the email was returned as "Undeliverable" will be maintained similar to 2.4.1 above with one exception: the employee will acknowledge by signature on a copy of the email marked "Undeliverable" the date on which he/she received the material.

2.5 Delivery to Non-Employees

2.5.1 Participants, beneficiaries, and other individuals entitled to receipt of required disclosures as identified by Title I of ERISA must provide their consent to receive required disclosures electronically. This will be accomplished by emailing those individuals and asking for their consent. The email must notify them of the type of information that they will receive through email, that the individuals may withdraw their consent at any time without charge for hard-copies, that consent may be withdrawn via email message to the University Human Resource Department or via letter through the US Postal Service, and they must provide a current mailing address, their rights to request a hard-copy of any document at any time, and any requirements (hardware or software) needed to receive the disclosures. The consent to receive required disclosures via email may be sent as an affirmative reply to the email sent or via US Postal service. For non-employees who do not have an email address in Human Resources, a hard-copy of the information will be sent to the last known address with notice that information can be sent via either email or hard-copy. Absent a reply all required disclosures will be sent Certified via US Postal Service.

2.5.2 Any changes in hardware or software requirements necessary to receive required disclosures via email must be resent per 2.5.1 above with a request for an additional consent.

2.5.3 Emails delivered and returned as "Undeliverable" will be treated the same as 2.4.2 with one exception: the hard-copy will be delivered Certified - Receipt Requested via US Postal Service.

3.0 AUTHORIZATION

The Director of Human Resources has the authority to change, modify or approve exceptions to this policy at any time with or without notice and with the approval of the President or designee. All employees must be subsequently notified of changes before they take effect.

4.0 ATTACHMENTS

N/A



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