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One 415 limit.

I would do a single test for the entire year. I don't think moving from MEP to MEP requires you to run separate tests. Even if there is some justification for running multiple tests (I'd love some examples where people think this is appropriate), I think you could rely on permissive aggregation.

When did compensation and contributions cease? I think that would be the relevant end date for testing.

Yikes. This boomer regrets the mistake!

The instructions state: “Filers of Form 5500-EZ are not required to file schedules or attachments related to Form 5500 with the 2020 Form 5500-EZ.” https://www.irs.gov/pub/irs-pdf/i5500ez.pdf The instructions leave open that a filer is permitted to file Schedule A.

As a proud Gen-Xer, I gotta take issue with the daily digest directing me here with a headline that this was affecting "millennials".... 😁

It is deductible. If you don't believe me have an actuary prepare a formal 404(a) valuation.

I take the position that the standard PCORI rules for an HRA integrated with a fully insured plan also apply to an ICHRA. So the employer must file the Form 720 and pay the PCORI fee for the employees (but not dependents) covered by the ICHRA. More details: https://www.theabdteam.com/blog/aca-pcori-fee-increases-to-2-66-for-2020-calendar-year-plans/ Does the PCORI Fee Apply to HRAs? Yes, an HRA is a self-insured health plan. However, the PCORI rules provide an exception to the fee requirement for an HRA where it is offered along with a self-insured major medical plan that has the same plan year as the HRA. This avoids the need to pay the PCORI fee for both the HRA and the self-insured major medical plan (i.e., each person covered by both plans is counted only once for purposes of determining the PCORI fee). There is no exception from the PCORI fee for an HRA offered along with fully insured major medical coverage. While the insurance carrier is responsible for paying the PCORI fee for the fully insured medical plan, the employer is responsible for paying the PCORI fee on the HRA. The IRS is essentially double-dipping in this scenario by imposing the PCORI fee on the same lives covered by both the major medical and the HRA. In recognition of this, the HRA PCORI fee paid by the employer is determined by counting only one life per employee participating in the plan (and not dependents). Summary: The PCORI fee is required for an HRA unless it is paired with a self-insured major medical plan that has the same plan year as the HRA. Where the PCORI fee is required, the employer is responsible for filing the Form 720 and paying the PCORI fee for an HRA solely for the covered employees (not dependents).

The impetus is on the participant to keep the Plan Administrator informed of whereabouts. DOL "aggression" is targeted at missing participants when benefits become due and payable, basically NRA and/or RBD. If a plan had optional early retirement at age 55, it wouldn't have to find and communicate with all TVPs upon attainment of age 55. I'm sorry I do not have a suggestion for dealing with what has already occurred other than "too bad, so sad, now you know why you should make sure we have your updated address." For future reference I can tell you that our window amendments now always have as an eligibility requirement that a participant must have an updated/correct address on file with the Plan Administrator and the PA is not responsible for missing participants/bad addresses - basically a CYA provision.