Advisory Opinions

Requests for interpretations and other rulings under Title 1 of ERISA are handled by the Office of Regulations and Interpretations under the provisions established by ERISA Procedure 76-1. The office answers inquiries from individuals and organizations in the form of advisory opinions, which apply the law to a specific set of facts, or information letters, which merely call attention to well established principles or interpretations.

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**1994**
AO/ Date/ Reference	Recipient	Description of Request
1994-12A 04/04/1994 3(33) 4(b)(2)	Ms. Mary M. Potter Matthews & Branscomb One Alamo Center 106 S. St. Mary's Street San Antonio, Texas 78205-3692	Whether benefit arrangements for employees of Morningside Ministries, an institution organized by the Episcopal Diocese of West Texas, the Southwest Conference of the United Methodist Church, and the Southwest Presbyterian Church of San Antonio, are church plans within the meaning of section 3(33) of Title I of the Employee Retirement Income Security Act of 1974 (ERISA).
1994-11A 03/23/1994 3(33) 4(b)(2)	Ms. Sharon L. Klingelsmith Drinker, Biddle & Reath Philadelphia National Bank Building 1345 Chestnut Street Philadelphia, Pennsylvania 19107-3496	Whether certain benefit arrangements for employees of Lancaster-Mennonite Hospitals, a mental health facility in Mount Gretna, Pennsylvania, which is an institution of the Mennonite Church, are church plans within the meaning of section 3(33) of Title I of ERISA.
1994-10A 03/17/1994 3(33) 4(b)(2)	Mr. Arnold B. Kogan Goldberg, Katzman, & Shipman, P.C. 320E Market Street Strawberry Square Harrisburg, Pennsylvania 17106-1266	Whether the benefit arrangements for Messiah Home, a retirement community located in Mechanicsburg, Pennsylvania, that is an institution of the Brethren in Christ Church, employees are church plans within the meaning of section 3(33) of Title I of ERISA.
1994-09A 03/17/1994 3(33) 4(b)(2)	Mr. John J. Hunter Stradley, Ronon, Stevens & Young 2600 One Commerce Square Philadelphia, Pennsylvania 19103-7098	Whether benefit arrangements for employees of the St. Peter's Hospital, an institution of the Religious Sisters of Mercy, and of other related institutions of the Order are church plans within the meaning of section 3(33) of Title I of ERISA.
1994-08A 03/17/1994 3(33) 4(b)(2)	Mr. Robert L. Abramowitz Morgan, Lewis & Bockius 2000 One Logan Square Philadelphia, Pennsylvania 19103-6993	Whether benefit arrangements for employees of The Nazareth Hospital, in Philadelphia, Pennsylvania, which is an institution of the Congregation of the Sisters of the Holy Family of Nazareth, Immaculate Conception Province, are church plans within the meaning of section 3(33) of Title I of ERISA.
1994-07A 03/14/1994 3(1) 3(5) 514(b)(6)(D)	Mr. Robert R. Googins Commissioner of Insurance P.O. Box 816 Hartford, CT 06142-0816	Whether an employee benefit arrangement sponsored by the United Service Association for Health Care (USA) and seven trusts established under the arrangement constitute "employee welfare benefit plans" within the meaning of section 3(1) of ERISA and whether they are "fully insured" within the meaning of section 514(b)(6)(D) of ERISA.
1994-06A 03/08/1994 3(33) 4(b)(2)	Mr. John P. Gallagher Schubert, Bellwoar, Mallon & Walheim 1400 Two Penn Center Plaza Philadelphia, Pennsylvania 19102-1890	Whether benefit arrangements for employees of the Sacred Heart Manor in Philadelphia, Pennsylvania, a nursing home of the Carmelite Sisters for the Aged and Infirm are church plans within the meaning of section 3(33) of Title I of ERISA.
1994-05A 03/08/1994 3(33) 4(b)(2)	Mr. Vincent P. Haley Schnader, Harrison, Segal & Lewis 1600 Market Street, Suite 3600 Philadelphia, Pennsylvania 19103	Whether benefit arrangements for employees of certain hospitals and other institutions of the Religious Sisters of Mercy are church plans within the meaning of section 3(33) of Title I of the Employee Retirement Income Security Act of 1974 (ERISA).
1994-04A 02/17/1994 3(33) 4(b)(2)	Mr. Robert L. Abramowitz Morgan, Lewis & Bockius 2000 One Logan Square Philadelphia, Pennsylvania 19103-6993	Whether benefit arrangements that twelve institutions of the Sisters of St. Francis of Philadelphia establish and maintain for their employees are church plans within the meaning of section 3(33) of Title I of the Employee Retirement Income Security Act of 1974 (ERISA).
1994-03A 02/17/1994 3(32) 4(b)(1)	Mr. John R. Whitehurst II Porter & Porter 2100 Central Trust Tower Cincinnati, Ohio 45202	Whether the Addison Community Hospital Employee Pension Plan is a governmental plan within the meaning of section 3(32) of Title I of ERISA and thus excluded by section 4(b)(1) from coverage by the requirements of Title I of ERISA.