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    Does an On-Site Employee Health Center disqualify employees from HSA eligibility?

    Guest ETX
    By Guest ETX,

    I have a client with an on-site health center that provides emergency care and treatment of minor illnesses and injuries. Can this client offer an HSA to its employees?


    New Regs?

    Guest Michael Anderson
    By Guest Michael Anderson,

    Does anyone know if the new 403(b) regs will affect 501©(3)'s in the same way? Thanks!


    May a charity be named as the beneficiary of a qualified plan?

    KateSmithPA
    By KateSmithPA,

    May a charity be named as the beneficiary of a qualified plan? Does it make any difference if it is a charitable trust?


    Insurance Contract Consent

    Guest kothe19
    By Guest kothe19,

    I have been reviewing the NAIC model law for quite sometime trying to determine the length of time a signature is valid. For instance, with a 403(b) transfer an application and transfer paperwork is signed on 1-1-05 at what point can you not accept those funds? Does this differ based on product? I know 403(b) life plans no longer exist, but if they did how far out could the effective date be from the signature date?

    If anyone has the website with these guidelines I would greatly appreciate it if you pasted the link.


    Control Group Testing Issue

    Guest jkrad
    By Guest jkrad,

    When you have a control group do you test each plan separately for the ADP/ACP or are they aggregated?


    Limits Under a Medical Expense Reimbursement Plan

    Guest Edward McElroy
    By Guest Edward McElroy,

    I seem to recall that there were limits as to the amounrt of benefits that could be reimbursed under a Medical Expense Reimbursement Account. I recall that these amounts were either $50,000 or 15% of compensation. Additionally, where in the Code are these amounts set out? Any assistence would be appreciated. Thanks. Ed


    Terminating a VEBA

    Randy Watson
    By Randy Watson,

    An employer uses a VEBA as a funding vehicle for its health plan. The employer wants to keep the health plan in place but terminate the VEBA. Other than following the termination procedures in the VEBA trust document, using the remaining assets to pay health benefits and filing a final 5500, is there anything else that should be done?


    Schedule A - "Additional compensation paid"

    Lori Friedman
    By Lori Friedman,

    I just received some Schedule A information that includes a page of "Supplemental Compensation Data".

    Certain amounts ("additional compensation paid") are provided for non-cash compensation, incentive plan payouts, and other items allocated to the policy and attributed to a broker and/or agent.

    Is anyone familiar? My initial thought is that "additional compensation paid" is just something extra to report on Schedule A, Line 2. But, the amounts are neither commissions nor fees, so they don't fit neatly into the form. Any thoughts?


    SPD Question

    Guest willow
    By Guest willow,

    I have just gotten a new client that has two 403(b) plans and two 401(a) plans. They are having a law firm draft the documents and when I asked if the law firm was also doing the SPD's they did not have an answer. They just checked with the law firm and the charge for the four SPD's will be between $11,000 - $12,000 (ouch!).

    Is anyone aware of any service that would take these documents and make an SPD?

    Thanks!

    Willow


    Cafeteria Plan Admin. training

    R. Butler
    By R. Butler,

    Does anyone have any recommendations on seminars for a beginner looking to learn the basics?

    Thanks in advance for any guidance.


    409A regulations

    Guest jigpsu100
    By Guest jigpsu100,

    Does anyone have an update on the new regulations? I thought they were scheduled to come out by the end of August. Someone must know something.


    Put options on Non-Marketable Securities

    Guest johnpetrancosta
    By Guest johnpetrancosta,

    We have one ESOP, it is for a privately held company. I was asked to do research on a new (i think) provision which allows the Sponsor (as opposed to he plan) to offer put options to buy back particpant ESOP shares for non-marketable securities. Does anyone have any information on this relating to mechanism, requirements, type of transaction etc? I confess to having very limited ESOP experience, so it might be easy to talk over my head. I thank you in advance for your time, consideration and patience.


    Plan amendments signed and submitted late to IRS

    k man
    By k man,

    the client had documents sitting around and decided to sign and send docs to IRS one year after receipt. by that point they were late. IRS wants client to pay 3000 dollar sanction rather than 750, the fee they would be eligible for had the submitted under VCP. their justification is they (the IRS) discovered the failure rather than the client bringing the error to the attention of the IRS through a VCP scenerio. I think this is unduly harsh under the circumstances. plan is small and plan sponsor did in effect turn himself in by submitting document. anyone have any suggestions on how to deal with the service on this?


    Simplified Creditable Coverage Test - Mail Order?

    Guest cstrong
    By Guest cstrong,

    I have a question about the simplified determination of creditable coverage test that was set forth in the CMS creditable coverage guidance. Specifically, a prescription drug plan is deemed to be creditable if it "provides reasonable access to retail providers, and optionally, for mail order coverage," among other things.

    Assuming a plan meets all the other requirements but doesn't provide mail order coverage, does this mean that the plan does not satisfy the simplified creditable coverage test? Alternatively, does a plan have to offer mail order coverage in order to meet the simplified creditable coverage test?

    Thank you in advance for any thoughts.


    Is it really going to happen on January 1, 2006?

    Guest PB&J
    By Guest PB&J,

    Is anyone 100% convinced that participants in a 403(b) plan will absolutely not be allowed to do a 90-24 transfer come January 1, 2006? Would you advise a client with a 403(b) plan who is switching providers to encourage participants, if they also want to switch providers, to do so NOW?


    ADP test in the year of acquisition

    Guest MikeD
    By Guest MikeD,

    I was wondering if anyone had any insight:

    - The assets of ABC Corp. are acquired by XYZ, LLC in April of 2005. ABC Corp. maintained a 401(k) profit sharing plan prior to the asset sale. The Plan used the prior-year testing method and, taking into account contribution rates for the NHCEs, the HCEs of ABC Corp. could have contributed 5% of pay (3% ADP for the NHCEs). XYZ, LLC took over the sponsorship of the Plan at the time of the acquisition.

    Is XYZ bound by the prior year testing results of ABC? In other words, are the HCEs of XYZ limited to 5%? Or, because it was an asset sale, is the Plan treated as if there was no prior year (therefore allowing us to assume 3% for the NHCEs and 5% for the HCEs)?

    And, for 2006, would XYZ use the ADP of the NHCEs for all of 2005 of just April-December?

    Thanks!


    401(k) contributions DURING military leave

    Guest HelpINeedSomeBody
    By Guest HelpINeedSomeBody,

    For tax reporting purposes, how would you report employee contributions to a 401(k) Plan for an employee who is on military leave but is receiving compensation from his employer to supplement his military pay to make it equal to what the employee received while actively working for the employer? Would you use a W-2 or a 1099?


    SFAS interest rates as of 6/30/2005

    Guest BDZ
    By Guest BDZ,

    Has anyone gotten any input on the range of acceptable interest and discount rates (particularly from auditors) for SFAS as of June 30, 2005?

    Sorry, I didn't think the first post went through.


    SFAS Interest Rates as of 6/30/2005

    Guest BDZ
    By Guest BDZ,

    Has anyone gotten any input on the range of acceptable interest and discount rates (particularly from auditors) for SFAS as of June 30, 2005?


    Providing a TPA quote when you are already the TPA

    Santo Gold
    By Santo Gold,

    Our firm works with many different financial advisors and performs only tpa services (no investment/insurance product sales). We are also approved/recommended tpa's for several larger fund families. Recently, we received an email from one of the mutual fund families requesting that we provide a fee quote on a plan that we already handle the admin for. An outside financial rep got in touch with the client and will be proposing new funds, options, etc, and the fund house contacted us requesting that we provide this rep with a quote.

    Can anyone offer their advice on how to proceed? To do nothing would jeopardize our tpa role in the plan, and yet to offer a quote would seem to be going behind the back of the current financial guy who brought us in. Our fee quote would likely be less than what they are currently paying since the new investment structure and platform would reduce the services that we provide.

    Any thoughts are greatly appreciated.


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