Leaderboard

Just as an FYI, reasonable cause penalty waivers are very hard to get nowadays. The reasonable cause better be damn good if you are going to gamble away your DFVCP eligibility. Like "all my plan records were trapped in the middle of disaster area and I filed the 5500 as soon as humanly possible after FEMA let us go get them" good.

The grace period for year one coverage does not affect the employee's contribution limit for year two coverage. The technical rules are in Prop. Treas. Reg. §1.125-1(e). But more useful is the IRS confirmation in its recent notice addressing the extended grace period option: IRS Notice 2021-15 https://www.irs.gov/pub/irs-drop/n-21-15.pdf If an employer adopts the § 214 carryover or the extended period for incurring claims permitted by § 214(c)(1) of the Act, the annual limits under §§ 125(i) and 129(a) apply to amounts contributed to a health FSA or dependent care assistance program for a particular year, and not to amounts reimbursed or otherwise available for reimbursement from a health FSA or dependent care assistance program in a particular plan or calendar year. Thus, unused amounts carried over from prior years or available during an extended period for incurring claims are not taken into account in determining the annual limit applicable for the following year.

The idea would be to replace the existing message boards with New BenefitsLink (click) -- what could possibly go wrong?

This is a union plan and we do have A&S benefits under the Welfare Plan, but the trustees were interested in ways to allow access to funds to supplement since this would not increase costs to the plan and the employees wouldn't need to pay premiums for another plan.

Thank you CuseFan. I thought the reason Groups 1 & 2 were showing up with zeroes in the ABT calculations had something to do with those plans not being safe harbor while the plans in the group we were testing (Group 3) are safe harbor. That made some sense in my mind with 1.401(k)-1(b)(4)(iii)(B). I have since found several sources that support what you've stated. This is why I come here when I'm not comfortable with what I'm seeing and why I recommend this board to everyone I know in the industry.

I'm not sure why that would be needed. Let the members link to their LinkedIn page is necessary - pr expand their profile. We tend to know who does what on this forum based on the questions and answers. Let's not *goober* up the thought leadership with sales. In my career, the ability to "sell" often doesn't correlate with expertise....

Hmmm. Well, not there yet, but it's only a number of months away... 😞 Just hoping I'm still needed and fed!

The average benefit percentage is calculated by considering ALL contributions to ALL plans within the CG, so the only people with zero rates anywhere should be those with zero deferral, zero match, and zero profit sharing/safe harbor/non-elective. Groups 1 & 2 are only zeroes for purposes of determining rate groups under the general test for nondiscrimination, which you should not need to do. If Plan 9 satisfies coverage and provides uniform percentage (design based safe harbor), you should be good, but you have one average benefit percentage for the entire control group that is based on all contributions. Yes, be mindful of BRFs.