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Just to confirm, we recently did a PBGC termination where the entire process was finished a day or two after the effective date of the termination. A word of caution, however: it's a really good idea to have a DETAILED schedule of what everyone needs to do when. It's easy to get off track and have the deadlines get away from you. This was especially true in our case (and probably most situations), because the process involved: the client (plan sponsor), the attorney (us), the TPA/actuary, and the investment advisor (who was working on the procurement of the annuities). It was clear to us from the beginning that everyone was underestimating their part of the project and the detailed to do list advised everyone of the details of their responsibilities and kept us all on track.

You might have a partial plan termination under these circumstances. If so it would require the terminated employees to become 100% vested.

Yep. Chart at https://benefitsattorney.com/charts/maximums/, showing limits from 1996 through 2021, has been updated.

Official figures: https://www.irs.gov/pub/irs-drop/n-20-79.pdf

@Ponderer33 Any individual covered by an HRA that is not specially designed to preserve HSA eligibility will have disqualifying coverage for HSA eligibility purposes. That means the individual will not be able to make or receive HSA contributions. The individual can still be covered by the HDHP. The same is true for a retiree HRA. If the HRA is not post-deductible, limited purpose, or suspended, the retiree and any covered dependents (i.e., any dependents whose health expenses are eligible for reimbursement through the HRA) will not be HSA-eligible. This is essentially the same issue as posed by an employee's health FSA enrollment. Overview here: https://www.theabdteam.com/blog/hsa-interaction-health-fsa-2/ In your situation, ideally there would be a plan feature in place permitting the retiree to elect to opt-out of/suspend coverage for any otherwise covered dependents if they want those dependents to maintain HSA eligibility. Otherwise, the retiree would have to opt-out of/suspend the HRA entirely to preserve HSA eligibility for covered dependents. Keep in mind that enrollment in any part of Medicare will also block HSA eligibility. Overview here: https://www.theabdteam.com/blog/how-medicare-affects-hsa-eligibility/ Here are a couple useful pieces of IRS guidance: IRS Rev. Rul. 2004-45: https://benefitslink.com/src/irs/revrul2004-45.pdf Under section 223, an eligible individual cannot be covered by a health plan that is not an HDHP unless that health plan provides permitted insurance, permitted coverage or preventive care. A health FSA and an HRA are health plans and constitute other coverage under section 223(c)(1)(A)(ii). Consequently, an individual who is covered by an HDHP and a health FSA or HRA that pays or reimburses section 213(d) medical expenses is generally not an eligible individual for the purpose of making contributions to an HSA. ... Retirement HRA. A retirement HRA that pays or reimburses only those medical expenses incurred after retirement (and no expenses incurred before retirement). In this case, the individual is an eligible individual for the purpose of making contributions to the HSA before retirement but loses eligibility for coverage periods when the retirement HRA may pay or reimburse section 213(d) medical expenses. Thus, after retirement, the individual is no longer an eligible individual for the purpose of the HSA. IRS Notice 2008-59: https://www.irs.gov/irb/2008-29_IRB#NOT-2008-59 Q-8. Is an individual with family HDHP coverage who is also covered by a post-deductible HRA or post-deductible health FSA an eligible individual under § 223(c)(1) if the post-deductible HRA or post-deductible health FSA reimburses § 213(d) medical expenses of a spouse or dependent incurred before the minimum family HDHP deductible under § 223(c)(2)(A)(i)(II) has been satisfied? A-8. No. If an individual with family HDHP coverage is covered by a post-deductible HRA or post-deductible health FSA that reimburses the § 213(d) medical expenses of any covered individual before the minimum family HDHP deductible under § 223(c)(2)(A)(i)(II) has been satisfied, that individual is not an eligible individual under § 223(c)(1). Example 1. Employee C has family HDHP coverage. Employee C’s spouse and children (but not Employee C) are also covered by non-HDHP family coverage provided by the spouse’s employer. Employee C and Employee C’s spouse and children are also covered by a post-deductible health FSA. The health FSA pays for unreimbursed medical expenses of the spouse and child without regard to the satisfaction of the deductible of the family HDHP. Because the health FSA covering Employee C reimburses medical expenses before the minimum family HDHP deductible is satisfied, Employee C is not an eligible individual. Example 2. Same facts as Example 1, except the health FSA does not cover Employee C. Employee C is an eligible individual.

At first thought, it seemed off. But, you are talking about such a short loss period that an extra day is a significant increase. If it is 4 days late and you add 1 more day, its a 25% increase. If it is 104 days late and you add 1 day, it is less than 1% increase. The math: 4/30 is $2.13 5/1 is $4.27 5/2 is $6.40 5/3 is $8.53 5/4 is $10.66 5/5 is $12.80 5/7 is $17.06 5/15 is $34.10 Counting 4/29 as a day in the loss period: Amount doubles from 2 days to 3 days (2.13 to 4.27) +1 day Amount doubles from 3 days to 5 days (4.27 to 8.53) +2 days Amount doubles from 5 days to 9 days (8.53 to 17.06) +4 days Amount doubles from 9 days to 17 days (17.06 to 34.10) +8 days The amount due doubles as the number of days late you add to the prior number of days doubles.

It's a per filing fee and your filing is supposed to correct all errors, so 2018 and 2019 all together. You/they should also review thoroughly for any other issues that may need correction and include as well.

This is not as cut and dried a question as you might think. In PEO world, there is always a question as to whether the real employer of the contractor is the staffing firm or the company the employee is being leased to. The first employer seems to be taking a stance that the only true employee of the company are the central office folks. Your client may have gotten a legal opinion that what they are doing is OK and, indeed, the only way they can manage the situation without becoming a MEP.

Any/all of our MP plans were either merged or restated into something else long, long ago. You have to maintain the accounts separately and keep the J&S annuity provisions on those accounts if the rest of the plan doesn't have them. Our (FTW) prototypes have a checkbox to indicate if such money exists and it triggers the necessary language in the SPD and elsewhere.