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
1994-22A 07/01/1994 2510.3-1(j) 3(1)	Ms. Catherine A. Powers Benefits Attorney Air Line Pilots Association 535 Herndon Parkway P.O. Box 1169 Herndon, Virginia 22070	Whether the Air Line Pilots Association, International (ALPA) Group Term Life Insurance Plan is an "employee welfare benefit plan" within the meaning of section 3(1) of ERISA.
1994-21A 06/17/1994 3(32)	Ms. Theresa L. Holmes Corporate Counsel Lexington Fayette Urban County Government 200 East Main Street Lexington, Kentucky 40507	Whether inclusion of employees of The Carnegie Center for Literacy and Learning in the County Employees Retirement Systems (CERS), a retirement system administered by the Kentucky Retirement Systems to provide retirement benefits to employees of counties and school boards in the State of Kentucky, would affect the status of CERS as a governmental plan within the meaning of section 3(32) of Title I of ERISA.
1994-20A 06/17/1994 3(40) 514(b)	Mr. Alfred W. Gross Deputy Commissioner Virginia Bureau of Insurance Box 1157 Richmond, Virginia 23209	Whether the Freedom Spirit program offered by Unitec Association which is insured by The Centennial Life Insurance Company is a multiple employer welfare arrangement (MEWA) within the meaning of section 3(40) of Title I of ERISA.
1994-19A 06/13/1994 3(32) 4(b)(1)	Mr. David R. Levin Reish & Luftman 11 Dupont Circle, Suite 775 Washington, D.C. 20036-1207	Whether the Appalachian Regional Commission Pension Plan is a governmental plan within the meaning of Title I of ERISA and thus is excluded by section 4(b)(1) from coverage by the requirements of Title I of ERISA.
1994-18A 05/23/1994 3(33) 4(b)(2)	Ms. Melissa B. Rasman Dechert Price & Rhoads 4000 Bell Atlantic Tower 1717 Arch Street Philadelphia, Pennsylvania 19103-2793	Whether certain benefit arrangements for the Theological Seminary of the Presbyterian Church (U.S.A.) a/k/a Princeton Theological Seminary's employees are church plans within the meaning of section 3(33) of Title I of ERISA.
1994-17A 04/29/1994 606(a)(1)	Mr. David A. Snouffer Willcox & Savage, PC 1800 Nations Bank center One Commercial Place Norfolk, Virginia 23510-2197	Whether, in complying with the notice requirement imposed by section 606(a)(1) of ERISA, with respect to the continuation of coverage provisions, such group health plans must provide the required notice not only to the covered employee, but also, in all cases, to the spouse of such employee, regardless of whether the spouse is covered under the group health plan.
1994-16A 04/20/1994 3(33) 4(b)(2)	Mr. S. Howard Kline Buchanan Ingersoll 600 Grant Street, 58th Floor Pittsburgh, Pennsylvania 15219-2887	Whether St. Anthony's Hospital in St. Petersburg, Florida, a medical facility of the Franciscan Sisters of Allegany, New York, benefit arrangements are church plans within the meaning of section 3(33) of Title I of the Employee Retirement Income Security Act of 1974 (ERISA).
1994-15A 04/20/1994 3(33) 4(b)(2)	Mr. I. Lee Falk Morgan, Lewis & Bockius 2000 One Logan Square Philadelphia, Pennsylvania 19103-6993	Whether certain benefit arrangements for employees of the Presbyterian Homes of the Presbytery of Huntingdon are church plans within the meaning of section 3(33) of Title I of the Employee Retirement Income Security Act of 1974 (ERISA).
1994-14A 04/20/1994 3(1)	Mr. Emil Steck, Jr. The Park Center Building 221 East Walnut Street, Suite 236 Pasadena, California 91101	Whether the Heat and Frost Insulators and Asbestos Workers Joint Apprenticeship Trust or the Heat and Frost Insulators and Asbestos Workers Maintenance and Hazardous Waste Agreements Trust are employee welfare benefit plans within the meaning of section 3(1) of Title I of ERISA, and if so, whether any ERISA reporting requirements are applicable to the plans.
1994-13A 04/04/1994 3(33) 4(b)(2)	Mr. I. Lee Falk Morgan, Lewis & Bockius 2000 One Logan Square	Whether benefit arrangements for the Lutheran Social Services--East Region (LSSER) in Lititz, Pennsylvania, an institution of the Evangelical Lutheran Church in America employees are church plans within the meaning of section 3(33) of Title I of the Employee Retirement Income Security Act of 1974 (ERISA).