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
1994-17A 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).
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.