Can the agreement be signed electronically?

Yes. Electronic signatures are enforceable under the federal ESIGN Act (15 U.S.C. ch. 96) and state UETA where adopted; ensure the signer demonstrates intent, consents to electronic records, attribution is clear, and records are retained.

When is notarization necessary?

Notarization is usually not required for standard participation agreements, but it may be necessary if the document conveys property rights, contains a power of attorney, or state law or plan rules require it.

Who must sign on behalf of an employer?

A named officer or authorized agent with corporate signing authority should sign; include a printed name and title in the signature block to demonstrate authority and avoid disputes.

How do I correct mistakes after signing?

Prepare an amendment or corrected agreement signed by all parties, or attach a signed erratum; do not alter the original signed PDF without a clear, signed replacement to maintain auditability.

Is there a required retention format?

Maintain a reproducible, tamper-evident record such as a signed PDF/A with an attached audit trail; this supports reproduction and evidentiary use in disputes or audits.

How do I revoke or cancel participation?

Follow the termination or revocation provisions in the agreement; document revocations in writing, signed by the revoking party, and retain the signed revocation alongside the original agreement.

Electronic Signature
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Plan Participation Agreement

Plan Participation Agreement

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Plan Participation Agreement

(Blue Cross and Blue Shield - Federal Employee Program)

Blue Cross and Blue Shield of Missouri

This Plan Participation Agreement is made and entered into between the Blue Cross and Blue Shield Association, an Illinois not-for-profit corporation ("Association"), and Blue Cross and Blue Shield of Missouri, a Missouri health services corporation ("Plan").

WHEREAS, the Plan has executed an agreement (identified as "Exhibit A") authorizing the Association to obligate the Plan to underwrite and administer benefits under Title 5, Chapter 89, United States Code (hereinafter referred to as the "Federal Employee Program" or "FEP"); and

WHEREAS, the Association has entered into Contract No. C.S. 1039 with the United States Office of Personnel Management (hereinafter referred to as "OPM"), for the provision of health care benefits under FEP (hereinafter referred to as the "Contract"), on behalf of the undersigned Plan and other Blue Cross and Blue Shield organizations (hereinafter referred to as "Participating Plans"); and

WHEREAS, it is desirable to set forth more fully the obligations and authorities of the Plan and the Association with respect to FEP,

NOW, THEREFORE, in consideration of the mutual obligations of the parties to this Agreement as hereinafter set forth, and in consideration of the execution of identical Agreements (excluding schedules specifying the areas to be serviced and underwritten by the Participating Plans) by other Participating Plans, it is agreed that:

1. Functions of the Association

The Association shall:

1.1. On behalf of the Plan, contract with the Office of Personnel Management to underwrite and administer health care benefits for FEP subscribers in consideration of subscription charges which are intended to maintain the sound financial condition of FEP.

1.2. Establish policies, practices, and procedures for the administration of FEP.

1.3. Interpret the provisions of the Contract.

1.4. Provide the Plan (at reasonable intervals and no less than annually) with financial reports reflecting the financial condition of FEP.

1.5. Make determinations with respect to (i) the Plan's FEP budget, (ii) resolution of issues arising from audits of the Plan with respect to FEP, (iii) the Plan's charges to the Contract, (iv) appeals from FEP benefits determinations by the Plan, and (v) lawsuits involving the Plan arising under the Contract.

1.6. Promptly provide to the Plan information needed to permit it to perform its functions under FEP and assist it in every reasonable way to administer its assigned functions.

1.7. Maintain the confidentiality of all information concerning the Plan which comes to the attention of the Association in the course of FEP reviews and audits of the Plan except as disclosure is required by law or is necessary for the administration of the Contract, and notify the Plan upon the Association's receipt of a request for Plan records under the Freedom of Information Act or upon receipt of a subpoena for such records.

1.8. Perform central administrative services for FEP directly or through an agent, including but no limited to receipt of subscription income, maintenance of central eligibility files, advertising, retention, investment, use and distribution of the Service Charge as specified in this Agreement, execution of contracts on behalf of Participating Plans with vendors, and arranging for the temporary underwriting and servicing of FEP benefits in an area not being serviced or underwritten by a Participating Plan.

2. Functions of the Plan

The Plan shall:

2.1. Underwrite and administer FEP benefits, in accordance with the terms of the Contract and in the manner set forth herein, as assigned pursuant to Schedule A.

2.2. Comply with the policies, practices, and procedures adopted by the Association for the administration and provision of benefits under FEP, including timely submission of the certification with respect to the Plan's data reflected in the Annual Accounting Statement to be submitted to OPM.

2.3. Comply with the Association's interpretations of the Contract.

2.4. Comply with the Association's determinations with respect to (i) questions involving the Plan's FEP budget, (ii) issues arising from audits of the Plan with respect to FEP, (iii) the Plan's charges to the Contract, (iv) appeals from FEP benefits determinations, and (v) lawsuits involving the Plan arising under the Contract.

2.5. Comply with the terms, provisions and conditions of the Contract, the Federal Employees Health Benefits Act [5 U.S.C. Ch. 89] and regulations issued thereunder, the Federal Acquisition Regulation [48 C.F.R.], and the Federal Employees Health Benefits Acquisition Regulation [48 C.F.R. Ch. 16].

2.6. Conform to all reasonable requests of the Association in connection with the administration of FEP, including providing OPM and the Association access to all of the Plan's records and other information relating to FEP.

2.7. Notify the Association of any occurrence or anticipated occurrence that might reasonably be expected to materially affect the Plan's ability to meet its obligations under the Contract.

2.8. Hold harmless and indemnify the officers, board of directors, Board of Managers of FEP, employees, and agents of the Association for all judgments, awards, liabilities, settlements, or other costs, including court costs, and taxes, interest and penalties.

3. Finances

3.1. Claims Expense

The Plan shall be reimbursed currently (to the extent funds are available) for the cost of health care benefits chargeable to the Contract, net of any refunds, rebates, allowances or other credits.

3.2. Administrative Expense

3.2.1. The Association's Administrative Expense.

The Association shall be reimbursed currently for chargeable FEP administrative expenses estimated to be incurred by it for the contract year.

3.2.2. The Plan's Administrative Expense.

The Plan shall be reimbursed currently for its estimated administrative costs chargeable to the Contract for the contract year, as determined by the Association.

3.3. Mandatory, Statutory Reserve Payments

The mandatory, statutory reserve payments incurred by the Plan for the contract year with respect to FEP claims allocated to the Plan shall be determined by the Association and paid to the Plan.

3.5. Service Charge

The Service Charge shall be allocated to Plans in the following manner:

3.5.1. One-half of the Service Charge remaining after an appropriation made pursuant to 3.5.2 will be allocated among the Participating Plans in the ratio of each Plan's contract months.

3.5.2. The Association may appropriate up to 50 percent of the Service Charge for purposes in the best interest of FEP.

3.5.3. The Plan's share of the unappropriated Service Charge shall be paid when the Association determines to distribute it.

3.6. Accounting

The income and expenses of FEP shall be determined for the contract year as follows...

3.7. Special Reserve

A positive balance in the FEP Special Reserve shall be available to offset subsequent losses and to increase benefits.

3.8. FEP liabilities of an insolvent Participating Plan.

4. Taxes Not Chargeable to the Contract

The Plan shall be liable for its proportionate share of any taxes, interest and penalties imposed on the Federal Employee Program which amounts are not chargeable to the Contract.

5. Areas of Responsibility for Claims Payments and Participation

5.1. The undersigned Plan shall underwrite FEP benefits as specified in Schedule A to this Agreement.

5.2. For the purpose of determining the undersigned Plan's share, if any, of any negative balance in the Special Reserve or of any unsatisfied liabilities, the total FEP claims allocated to the Plan for a contract year shall be the total benefits underwritten by the Plan as provided in Schedule A.

6. Delegation of Authority

6.1. The Association may delegate its functions under this Agreement.

6.2.1. Only Blue Cross and Blue Shield Plans or their wholly-owned affiliates are authorized to perform the functions set forth in this Agreement.

6.2.2. The rights and duties of the Plan set forth in this Agreement may not be delegated, assigned or transferred by the Plan without express written approval.

7. Definitions

Terms used in this Agreement shall have the same meaning that they have in the Contract.

8. Integration

This Agreement, together with its Schedule A and Exhibit A to the Contract with OPM, constitutes the entire agreement between the parties.

9. Amendment of Agreement

9.1. This Agreement may be amended by the mutual agreement of the parties.

9.2. The Agreement may be amended by the following process...

10. Termination of Agreement

10.1. This Agreement may be terminated without cause by either party by giving notice at least 120 days prior to the last day of the then current contract term.

10.2. The Association may terminate this Agreement if the Plan's license to use the Blue Cross or Blue Shield licensed mark(s) and name(s) is terminated.

10.3. If the Plan elects not to be bound by an amendment made pursuant to Section 9.2, this Agreement will terminate.

10.4. The parties understand that it may be necessary for the Plan to continue to perform obligations following the effective date of termination.

10.5. Termination of this Agreement automatically will terminate the power of attorney given to the Association by the Plan.

11. Appeals

The Plan may appeal to the Board of Managers if it disagrees with the Association's decision and may appeal to the Board of Directors if it disagrees with the Board of Managers' decision on appeal.

12. Partnership Not Intended

Nothing in this Agreement is intended to constitute a partnership or joint venture between the parties.

13. Law Governing and Severability

This Agreement shall be governed by the laws of the state of Illinois.

14. Notices

Notices made pursuant to this Agreement shall be sent by first class mail, postage prepaid, to the address of the party specified below on the signature page of this Agreement.

15. Force Majeure

Neither party shall be liable for damages due to delay or failure to perform any obligation under this Agreement if such delay or failure results from circumstances beyond the control of such party.

This Agreement may be executed in counterparts and shall be effective as of January 1, 1995.

BLUE CROSS AND BLUE SHIELD ASSOCIATION

By:

Print Name:

Title:

Address:

Date:

BLUE CROSS AND BLUE SHIELD OF MISSOURI

By:

Print Name:

Title:

Address:

Date:

What the Plan Participation Agreement Is and Covers

The Plan Participation Agreement is a formal contract that records an individual’s or entity’s decision to join and participate in a specified plan, such as an employee benefit plan, retirement arrangement, or vendor participation program. It sets eligibility rules, enrollment dates, contribution or fee obligations, voting or consent rights, termination procedures, and notice requirements. The document serves as evidence of consent and creates enforceable obligations between the participant and plan sponsor; when executed electronically it must meet federal and state electronic signature laws to be enforceable.

Why a Clear Agreement Matters

A properly completed Plan Participation Agreement documents consent, clarifies duties, and reduces disputes by recording election, contribution, and termination terms in writing. It also supports regulatory compliance and auditability when administering benefits or vendor programs.

Who Typically Prepares and Signs This Agreement

Typical users include plan sponsors, HR administrators, plan participants, and third-party administrators who manage enrollment, contributions, and compliance.

Plan sponsors and employers who establish eligibility, contribution schedules, and plan governance and need written consent.
Human resources and benefits teams responsible for enrollment processing, recordkeeping, and required regulatory reporting.
Individual participants or beneficiaries who must accept plan terms, authorize deductions, and confirm elections in writing.

Different roles handle distinct tasks: sponsors set plan rules, administrators process enrollments, and participants provide required information and signatures.

Stepwise Completion and Submission Process

Complete these steps in order to ensure the agreement is valid, routed, and archived correctly.

01

Gather Documents: Collect plan summary, ID, and any required attachments.
02

Fill Required Fields: Enter names, dates, plan details, and contribution elections.
03

Authenticate Signer: Choose appropriate signer authentication before signing.
04

Submit and Archive: Route signed copy to plan admin and store audit trail.

Online Workflow Settings to Use for Electronic Completion

Configure an electronic workflow that enforces signing order, captures authentication, and retains a tamper-evident audit trail.

Field	Configuration
Signing Order	Participant \| Plan administrator
Authentication	Email link plus optional SMS code
Reminders	Three automated reminders every 3 days
Storage Format	PDF/A with audit trail attached

How Electronic Signing Usually Works

A standard e-sign workflow keeps the document secure, records actions, and delivers copies to all parties automatically.

Upload Document: Sender uploads the agreement and attachments.
Assign Roles: Place sign, date, and initial fields for each role.
Signer Authentication: Signer confirms identity via email, SMS, or KBA.
Completion & Archive: Signed PDF and audit trail stored for records.

Technical Requirements for Digital Submission

Use a platform that provides secure e-signatures, detailed audit trails, and integrations with HR or document management systems.

Integrations: HRIS, payroll, cloud storage, and ERP
Authentication: Email, SMS code, or knowledge-based options
File Support: PDF and DOCX for editable and locked formats

Common Timing and Processing Expectations

Timelines vary by plan and employer; confirm specific windows and payroll cutoffs before submitting an election or change.

Open Enrollment Window:

Employer-defined period for initial or annual elections.

Effective Date:

As stated on the agreement or next payroll period.

Employer Processing:

Plan admin typically processes within one pay cycle.

Change Request Deadline:

Mid-year changes allowed only for qualifying events.

Tax Reporting Timeline:

Employer must retain records for tax reporting and audits.

Penalties and Risks from Errors or Omissions

Loss of Benefits: Missed elections become irrevocable

Tax Withholding Errors: Incorrect TIN triggers backup withholding

Reporting Penalties: Late filings invoke IRC §6721 penalties

Enrollment Rejection: Application may be denied or delayed

Legal Disputes: Contract interpretation may require counsel

PHI Exposure: Improper handling risks HIPAA BAA liability

Common Preparation Mistakes to Avoid

Entering nicknames or abbreviated names that do not match government IDs or payroll records, causing verification and tax reporting delays.
Failing to specify an effective date or using ambiguous date formats that create processing ambiguity and potential disputes about coverage timing.
Omitting required attachments or signatures for dependent coverage or beneficiary designations, which can invalidate elections or benefits claims.
Not retaining a signed copy with the audit trail and metadata, increasing administrative burden during audits or benefit disputes.

Security and Compliance Features to Expect

Encryption: TLS 1.2/1.3 in transit, AES-256 at rest

Audit Trail: Detailed timestamped signer actions

HIPAA Support: BAA available when handling PHI

Authentication: Email, SMS, or advanced methods

Certifications: SOC 2 Type II and ISO 27001

Accessibility: WCAG 2.0 Level AA support

eSignature Vendor Pricing and Feature Snapshot

Comparison of common commercial eSignature options for completing Plan Participation Agreements; signNow is listed first to align vendor ordering conventions.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	7-day free trial	Varies by vendor	Varies by vendor	Varies by plan	Varies by plan
Bulk Send	Yes (tier dependent)	Yes	Yes	Yes	Yes
Audit Trail	Yes	Yes	Yes	Yes	Yes
HIPAA Compliant	Yes	Yes	Yes	No	No

Frequently Asked Questions About Plan Participation Agreements

Answers to commonly asked questions about validity, e-signing, notarization, recordkeeping, and corrections for Plan Participation Agreements.

Need help? Contact support

Can the agreement be signed electronically?
Yes. Electronic signatures are enforceable under the federal ESIGN Act (15 U.S.C. ch. 96) and state UETA where adopted; ensure the signer demonstrates intent, consents to electronic records, attribution is clear, and records are retained.
When is notarization necessary?
Notarization is usually not required for standard participation agreements, but it may be necessary if the document conveys property rights, contains a power of attorney, or state law or plan rules require it.
Who must sign on behalf of an employer?
A named officer or authorized agent with corporate signing authority should sign; include a printed name and title in the signature block to demonstrate authority and avoid disputes.
How do I correct mistakes after signing?
Prepare an amendment or corrected agreement signed by all parties, or attach a signed erratum; do not alter the original signed PDF without a clear, signed replacement to maintain auditability.
Is there a required retention format?
Maintain a reproducible, tamper-evident record such as a signed PDF/A with an attached audit trail; this supports reproduction and evidentiary use in disputes or audits.
How do I revoke or cancel participation?
Follow the termination or revocation provisions in the agreement; document revocations in writing, signed by the revoking party, and retain the signed revocation alongside the original agreement.

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