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105(h) testing with different locations/levels of benefits


Guest RMW

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Company has 23 business units, across 5 states. Employees in different states are enrolled in different plans, with varying levels of premiums and benefits covered. Most are employed in Ohio, covered under the company's self-funded plan. Employees in the other states are covered under either a fully insured PPO or self-funded PPO.

For purposes of 105(h) testing, I have several questions:

1) Must the employees covered under the fully insured plans be included in either the eligibility or coverage parts of the test? If not, is there a reason an employer would want to?

2) Must the amount of employee paid premiums be the same for all employees, in every location, to avoid an excess reimbursement for HCE's?

3) Must the actual benefits provided be the same for all employees to avoid an excess reimbursement for HCE's? I do see the exceptions in the regs for diagnostic tests, etc.

4) If the answer is yes, how can this issue be resolved for a business with multiple locations which may require different plans for budgetary reasons, claims experience, etc?

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