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At last. Now you could make the commute from a residence in Poland from the other thread.

This is where I get to say I am sooooooo ooolllddd that I remember things that never were, maybe. I seem to recall that at some time in the distant past, if NO officer made over the dollar limit, then the highest paid officer was considered key. However, reseaching 1.416, 416, and the Erisa Outline Book, I see no mention of this. So do I chalk this up to Fawlty Towers, that is faulty memory or did it change when I wasn't looking? Maybe this should be posted under humor.

This reminds me of General Patton, who corresponded quite a bit during his career with much of it compiled in a two volume series "The Patton Papers". As I recall, he got a letter from someone with a whole bowl of alphabet soup after his name. He addressed his reply to the sender something like "John Smith, SOB".

Did he add FOS to the end?

GMK is correct, but please check your plan documents for the definition of a dependent. It is possible that your company has elected to offer coverage down to this level...highly unlikely but well worth the 5 minutes it will take for you to research.

I've always thought of ASPPA's QKA, QPA, CPC line as cumulative, so would only routinely use the highest one attained. ERPA is a separate ticket of course.

Be careful. If you look at the guidance, you might find that it is OK for the employer to cover a per capita fee at different rates for employees than for former employees. If there is a $50 fee, the employer can cover $10 for the employee and zero for the former employee. That makes for an account charge of $40 to the employees and $50 to the former employees, but the fee is still the same for each participant.

Some plans provide for the amount to be forfeited rather than appear to pay a TPA for a service that is not rendered. I would prefer to defend a forfeiture that is used for the benefit of participants in some way.