Is a Self-Funded STD Plan an ERISA Plan or an Exempt Payroll Practice?

ERISA generally governs all pension and welfare benefit plans. In regulations, the Department of Labor (“DOL”) has exempted certain types of plans or practices from the definition of a welfare benefit plan under Title I of ERISA.  One commonly used exemption is the “payroll practice” exemption.  Exempt payroll practices include “payment of an employee’s normal …