OPS-SOP-013 — Employer Offboarding & Plan Termination

This SOP establishes the standardized process for offboarding a participating employer from the Unity Care Member Plan Master Trust, including termination of plan coverage, COBRA notifications, vendor deactivation, financial reconciliation, trust sub-account close-out, and document retention. The goal is to protect plan participants, minimize legal exposure, and ensure ERISA compliance throughout the wind-down process.

Applies to all circumstances under which a participating employer exits the Unity Care plan, including:

Voluntary Termination — employer elects to terminate participation with proper notice
Non-Renewal — employer does not renew at the end of the plan year
Involuntary Termination for Non-Payment — employer fails to remit contributions and is terminated per the plan document
Involuntary Termination for Other Cause — employer terminated for material breach or regulatory violation

Role	Responsibility
Operations	Manages end-to-end offboarding checklist; coordinates with all vendors; drafts and routes notices
Finance	Reconciles final invoices; closes trust sub-account; coordinates with captive cell wind-down
Legal (Dickinson Wright PLLC)	Reviews termination notice language; advises on ERISA obligations; coordinates if litigation risk exists
Allied Benefit Systems (Kim James)	Processes plan termination; manages run-out claims period; issues final claims register
ProAct (Dolores Hynes)	Terminates PBM coverage; confirms final claims processed
Varipro	Triggers COBRA election notices for all qualified beneficiaries; manages COBRA administration through run-out
Broker (Spartan Wealth / Kaylin Konja)	Notified of termination; assists with employee communications where applicable
Employer (Plan Administrator)	Issues required employee notices; cooperates with data requests; settles final balance

Type	Notice Requirement	Who Initiates	Notes
Voluntary Termination	30 days written notice to Unity Care Operations	Employer	Termination date may not precede end of claims payment cycle per TPA agreement
Non-Renewal	30 days prior to plan anniversary; mutual confirmation required	Either party	Operations sends renewal reminder 60 days in advance; non-response treated as non-renewal after 30-day notice
Non-Payment Termination	Written cure notice (10 days); termination notice (5 days after cure period)	Unity Care Operations	Legal must review before issuing termination notice; document all payment history
For-Cause Termination	Per plan document and legal counsel guidance	Unity Care Operations + Legal	Coordinate with Dickinson Wright before any action

ERISA Notice Obligation: The employer (as Plan Administrator) must provide timely notice to covered employees of plan termination. Operations must confirm the employer has issued or will issue the required notices. Failure to notify participants is a fiduciary breach and potential DOL violation.

Day / Milestone	Action	Owner	Status
Day 0 — Termination Confirmed	Log termination in employer record. Confirm termination date, type, and coverage end date. Notify all internal stakeholders.	Operations	[ ]
Day 0–2	Notify Allied Benefit Systems (Kim James) of employer termination date. Request confirmation of final claims run-out period.	Operations	[ ]
Day 0–2	Notify ProAct (Dolores Hynes) of termination date. Confirm final claims cycle and PBM termination date.	Operations	[ ]
Day 0–2	Notify Varipro of termination. Provide employee roster for COBRA qualification. Confirm COBRA notice mailing timeline (COBRA notices required within 14 days of employer's 30-day notice to TPA).	Operations	[ ]
Day 0–2	Notify Spartan Wealth (Kaylin Konja) broker of termination.	Operations	[ ]
Day 1–3	Remove employer and employees from Employee Navigator. Confirm deactivation date matches coverage end date.	Operations	[ ]
Day 1–5	Review Legal if for-cause or non-payment termination. Dickinson Wright to review all termination notices.	Operations + Legal	[ ]
Coverage End Date	Coverage terminates. Allied confirms member ID deactivation. ProAct confirms PBM deactivation.	Allied / ProAct	[ ]
Run-Out Start	Claims run-out period begins. Allied processes claims incurred on or before coverage end date for [TBD] days.	Allied Benefit Systems	[ ]
Run-Out End [TBD]	Allied issues final claims register. Operations reviews and confirms all claims are settled.	Operations / Allied	[ ]
Post Run-Out — Finance	Final invoice reconciliation: reconcile all outstanding invoices, employer contributions, and trust sub-account balance.	Finance	[ ]
Post Run-Out — Finance	Issue final statement to employer. Collect any outstanding balances. Refund any overpayments per plan document terms.	Finance	[ ]
Post Run-Out — Finance	Close trust sub-account in Acumatica. Confirm with Trust administrator.	Finance	[ ]
Post Run-Out — Captive	Initiate captive cell wind-down for employer's protected cell. Coordinate with Unity Care Solutions – TN, LLC and SRS (or captive manager).	Finance + Operations	[ ]
Post Run-Out — Reinsurance	Notify Jason Strain (Brown & Brown / HLRA) of plan termination. Confirm no outstanding stop-loss claims or run-out obligations under reinsurance agreement.	Operations	[ ]
60 Days Post-Coverage	Confirm all COBRA elections received by Varipro. Confirm COBRA administration is active for elected participants.	Operations / Varipro	[ ]
File Close	Archive all employer documents, notices, claims register, final reconciliation, and wind-down confirmation. Retain per document retention policy (7 years minimum).	Operations	[ ]

TBD: Claims run-out period duration to be confirmed with Allied Benefit Systems (Kim James) and documented in the TPA agreement. Standard is 90–180 days; exact period must be specified here upon adoption.

COBRA is mandatory. Any qualifying event — including plan termination — that causes a covered employee or dependent to lose coverage triggers COBRA election rights. Operations must ensure Varipro is notified immediately upon confirmation of coverage termination.

Employer (as Plan Administrator) must notify Varipro of the qualifying event within 30 days
Varipro issues COBRA election notices to all qualified beneficiaries within 14 days of employer notification
Qualified beneficiaries have 60 days to elect COBRA coverage
Operations confirms with Varipro that notices are sent and receipt is documented
Failure to provide timely COBRA notices exposes the Plan Administrator and Unity to significant penalties

The following documents must be retained for a minimum of 7 years following the plan termination date, per ERISA and IRS requirements:

Termination notice (from employer or to employer)
All participant notices (COBRA, coverage termination)
Final claims register from Allied Benefit Systems
Final invoice and reconciliation documents
Trust sub-account close-out confirmation
Captive cell wind-down documentation
Correspondence with all vendors regarding termination

OPS-SOP-010 — Vendor Invoice Control & Payment Authorization
OPS-SOP-026 — GL Structure & Monthly Reconciliation
Unity Care Member Plan Master Trust document
TPA Agreement — Allied Benefit Systems
COBRA Administration Agreement — Varipro

Document IDOPS-SOP-013	Version1.0	Effective Date[TBD — upon adoption]	Next ReviewAnnually	OwnerOperations
Prepared ByOperations

OPS-SOP-013 — Employer Offboarding & Plan Termination

1. Purpose

2. Scope

3. Roles & Responsibilities

4. Termination Types & Notice Requirements

5. Offboarding Checklist & Timeline

6. COBRA Obligations

7. Document Retention

8. Related Documents