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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**1995**
AO/ Date/ Reference	Recipient	Description of Request
1995-15A 06/26/1995	Mr. Dennis J. Murphy Schwartz, Steinsapir, Dohrman & Sommers 3850 Wilshire Boulevard, Suite 1820 Los Angeles, California 90010-2594	Whether the Central Valley Schools Health and Welfare Benefit Trust constitutes a “governmental plan,” as defined in ERISA section 3(32), and is, therefore, excluded from coverage under Title I of ERISA.
1995-14A 06/26/1995	Ms. Barbara E. Tretheway Gray, Plant, Mooty, Mooty & Bennett, P.A. 3400 City Center 33 South Sixth Street Minneapolis, Minnesota 55402	Whether the Minnesota Public Employees' Insurance Plan constitutes a “governmental plan”, as defined in ERISA section 3(32) and is, therefore, excluded from coverage under Title I of ERISA.
1995-13A 06/19/1995 3(33) 4(b)(2)	Mr. S. Howard Kline Buchanan Ingersoll 600 Grant Street, 58th Floor Pittsburgh, Pennsylvania 15219-2887	Whether the Mercy Life Center Corporation Pension Plan is a “church plan” within the meaning of ERISA section 3(33) , and pursuant to section 4(b)(2) thereof, is not required to comply with the provisions of Title I.
1995-12A 06/19/1995 3(33) 4(b)(2)	Mr. S. Howard Kline Buchanan Ingersoll 600 Grant Street, 58th Floor Pittsburgh, Pennsylvania 15219-2887	Whether the Employees' Retirement Plan of the Sisters of the Good Shepherd is a “church plan” within the meaning of section 3(33) of Title I of ERISA and thus excluded from the requirements of Title I by section 4(b)(2).
1995-11A 06/16/1995 3(32) 4(b)(1)	Mr. Richard A. Gilbert Orrick, Herrington & Sutcliffe Old Federal Reserve Bank Building 400 Sansome Street San Francisco, California 94111-3143	Whether the status of the California State Teachers' Retirement System as a “governmental plan” within the meaning of ERISA sections 3(32) and 4(b)(1) would be adversely affected by accepting contributions pursuant to state law from a charter school’s operation where contributions were made on behalf of its employees for the limited period that the school's charter was in effect and were made so the school’s employees may participate in CSTRS for that same period.
1995-10A 06/16/1995 3(33) 4(b)(2)	Mr. James F. Podheiser Stradley Ronon Stevens & Young 2600 Commerce Square Philadelphia, Pennsylvania 19103-7098	Whether benefit plans for the employees of St. Joseph's University in Philadelphia, Pennsylvania, an institution of the Jesuit Fathers and Brothers, are “church plans” within the meaning of ERISA section 3(33).
1995-09A 06/16/1995 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 Archmere Academy, Inc., an institution of the Canons Regular of Premontre a/k/a the Norbertine Fathers, are “church plans” within the meaning of ERISA section 3(33).
1995-08A 06/16/1995 3(33) 4(b)(2)	Ms. Anne E. Moran Miller & Chevalier 655 Fifteenth Street, N.W. Suite 900 Washington, D.C. 20005-5701	Whether the health benefit plans of eight institutions of the Sisters of St. Francis of the Perpetual Adoration are “church plans” within the meaning of ERISA section 3(33) and are thus excluded from ERISA Title I requirements by section 4(b)(2).
1995-07A 03/06/1995 3(33) 4(b)(2)	Mr. Gair Petrie Paine, Hamblen, Coffin, Brooke & Miller Suite 1200, Washington Trust Financial Center 717 West Sprague Avenue Spokane, Washington 99204-0464	Whether the Providence Services Pension Plan is a “church plan” or plans within the meaning of ERISA section 3(33) where Providence Services is an institution of St. Ignatius Province of the Sisters of Providence.
1995-06A 05/18/1995 3(40) 514(b)(6)	Mr. Tom Portier Compliance Examiner Louisiana Department of Insurance P.O. Box 94214 Baton Rouge, Louisiana 70804-9214	Whether Mid-Continent Medical Benefits Trust, administered by Profession Administration Group, is a “multiple employer welfare arrangement” within the meaning of ERISA section 3(40)(A).