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Just because the compensation definition fails doesn't necessarily mean that there is a failure. Just do the test using a non-discriminatory definition of compensation and see if you pass. If you do there's nothing to do. If you don't then the 11g amendment looks good.

I don't think you need to amend the comp definition, if that's what you're asking. Just increase the contributions using an -11g amendment.

Here's an interesting contrary position on activity-only vs. outcome based that I disagree with (footnote 3): https://img.response.aonunited.com/Web/AonUnited/{08b033f5-e994-4f61-bc08-1963325664fc}_LR-F-Aug-21_Implications_of_Charging_Unvaccinated_Employees_More.pdf Some practitioners may argue that a wellness program that requires an individual to be vaccinated against COVID-19 in order to pay a reduced premium amount is an activity-based wellness program because the program is requiring the participant to undertake a certain activity related to a health status (i.e., get vaccinated). However, we think the better argument is that the program required the participant to obtain or maintain a certain status (i.e., being vaccinated) in order to receive the reduced premium amount. Therefore, it is an outcomes-based program. This is similar to a program that provides for reduced premiums for non-tobacco users, which are outcomes-based programs, based on the participant's status as a non-tobacco user. As noted above, outcome-based wellness programs must provide a reasonable alternative standard for anyone who does not meet the initial standard. I disagree because with the vaccine you simply complete the activity of taking the shot(s). But there’s no requirement to attain or maintain a specific health outcome. It’s not like attaining or maintaining a certain BMI. Smoking cessation requires a continuing obligation for the individual. I don’t see that as analogous. "Being vaccinated" requires no additional steps to maintain that outcome. It’s not just an academic point. The ability to get a reasonable alternative standard regardless of whether taking the vaccine is unreasonably difficult due to a medical condition or medically inadvisable to attempt is probably a major issue for many employers. That right applies only if you treat the vaccine incentive as outcome-based (as opposed to activity-only). See slides 12 and 26 here for a quick overview: 2021 ABD Wellness Program Guide

It's a Relius issue. From Relius: FIS has identified an issue impacting a selection of Form 5500 series EFAST submissions for form year 2020. Form 5500 series filings with internal attachments created using Relius Government Forms (RGF) software templates did not include those attachments in the electronic submission to EFAST. Pursuant to direction from the US Department of Labor (DOL), FIS will resubmit the impacted Form 5500 series forms, with attachments, to EFAST on behalf of all impacted plans. The DOL has indicated that they intend to take no further action against plans impacted by the incomplete electronic submissions. FIS has identified an issue impacting a selection of Form 5500 series EFAST submissions for form year 2020 that included internal attachments. Internal attachments are attachments to the Form 5500 created using templates in RGF ASP. The most commonly generated internal attachments are the reasonable cause explanation for late filing, the schedule of assets, the weighted average retirement age, and the CSEC participating employer list. It was discovered that internal attachments were not included in the electronic data transmission to EFAST for 2020 form year submissions. This issue was remediated in RGF ASP on August 17, 2020 for Form 5500 and Form 5500-SF filings, and on August 19, 2021 for Form 5500-EZ filings. Any form year 2020 filings with internal attachments, filed prior to remediation would have been impacted. As providers of EFAST-certified software, FIS has worked with EFAST and the DOL to address this issue. FIS has provided the DOL with a list of all impacted EFAST submissions and the DOL has directed FIS to automatically resubmit the impacted forms with the attachments. FIS will resubmit the impacted filings the week of August 23, 2021. No action is required from your firm or plan sponsors for the resubmission process. The DOL recognizes that the plan sponsors and administrators signed the Form 5500 filings with the attachments and it was the data transmission process that excluded these internal attachments. Accordingly, the DOL informed FIS that they will take no actions against impacted plans based on the omitted attachments. The DOL will notify the IRS, and while unlikely, it is possible your clients may receive a notice from the IRS or DOL regarding the missing attachments. FIS has posted here a "reasonable cause" letter that can be used in response to any such inquiries. IMPORTANT: The DOL indicated the initial submissions (with the omitted attachments) cannot be deleted from EFAST, and once the filings are resubmitted, both filings will be visible on the EFAST website. Please contact Customer Care for a listing of your customers impacted by this issue, if needed. FIS will resubmit impacted Form 5500 filings via EFAST during the week of August 23, 2021. All Form 5500 EFAST transmissions submitted after August 19, 2021 will include the associated attachments.

The lifetime income amount is equal to the account balance divided by the annuity purchase rate (APR). The APR is calculated actuarially and is based on the age, survivor benefit, assumed interest rate, and assumed mortality. Your valuation software may be able to calculate the APR from these inputs. For example here is a screenshot showing the calculation of the 100% J&S factor using the 2021 417(e) table and the 10-year treasury rate as of 8/2/2021 in ASC: If the participant's account balance was $100,000 as of the 8/31/2021 statement, the J&S lifetime income amount would be 100,000 / 252.208 = $396.50.

There is no basis for a return of contributions, or transfer. "I changed my mind" is not a mistake of fact. If the contribution was made in 2021, then just say 17100 was for 2020 and the rest for 2021. Schwab may or may not reflect that in their records, but those records (IMO) are unofficial and simply a convenience for their clients to keep track of things. If the contribution was made in 2020 I think you are stuck with a nondeductible contribution...actually I think it is worse than that, you simply can't max the DB contribution.