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.
AO/ Date/ Reference | Recipient | Description of Request |
---|---|---|
04/04/1994
3(33) 4(b)(2) |
Ms. Mary M. Potter |
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). |
03/23/1994
3(33) 4(b)(2) |
Ms. Sharon L. Klingelsmith |
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. |
03/17/1994
3(33) 4(b)(2) |
Mr. Arnold B. Kogan |
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. |
03/17/1994
3(33) 4(b)(2) |
Mr. John J. Hunter |
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. |
03/17/1994
3(33) 4(b)(2) |
Mr. Robert L. Abramowitz |
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. |
03/14/1994
3(1) 3(5) 514(b)(6)(D) |
Mr. Robert R. Googins |
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. |
03/08/1994
3(33) 4(b)(2) |
Mr. John P. Gallagher |
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. |
03/08/1994
3(33) 4(b)(2) |
Mr. Vincent P. Haley |
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). |
02/17/1994
3(33) 4(b)(2) |
Mr. Robert L. Abramowitz |
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). |
02/17/1994
3(32) 4(b)(1) |
Mr. John R. Whitehurst II |
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. |