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Employers may offer benefits with different eligibility periods. Should we define each of those eligibility periods for each of the benefits within the Wrap Document?

The RTO Benefits wrap document is intended to provide a comprehensive back-stop to each employer's underlying benefit programs and existing policy documents. It is designed to supplement, not replace, underlying policy/benefit design issues. To the extent that any particular benefit provides distinctly different eligibility, waiting period or other conditions on coverage from any other specific benefit item, the terms and conditions of the underlying benefit plan/policy document controls. Such provisions under the wrap document are merely intended to supplement those underlying benefit plan/policy documents to provide such Plan provisions in compliance with applicable federal law to the extent not otherwise addressed in a similar manner within the underlying benefit program document. It is not required or intended that the wrap would provide a comprehensive, alternative listing of separate benefit provisions that are otherwise contained in the underlying benefit plan/policy documents.

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