Benefits 101

For a Form 5500... let's say the year end 2022 plan assets (snapshot as of 11:59PM on December 31, 2022) was $652,325. However, profit sharing contributions / contributions attributable to the 2022 PLAN YEAR are made on March 2nd of 2023 FOR the 2022 plan year. Those assets deposited on 3/2/23 for the 2022 PLAN YEAR... SHOULD THEY be included in the "year end plan assets 2022" for the 2022 Form 5500? I just want to double check question this with the wisdom of the crowd here.

Great thanks. This is for a temp staffing firm so 99% of the employees are new hires.

IF we used a 12 month look back period to determine "eligibility".... do we need to issue Form 1095C to people who were not employed for a full 12 months? https://www.irs.gov/affordable-care-act/employers/questions-and-answers-about-information-reporting-by-employers-on-form-1094-c-and-form-1095-c That link FAQ question #6 seems to say if they were not a "full time employee" at any point, we don't need to issue a 1095C. Since we use that 12 month look back period to determine "full time"... it seems like any employee not employed for at least 12 months is categorically NOT full time. Thoughts?

Thanks! Can you offer some guidance to some law / IRS code / FAQ? I've received a myriad of conflicting answers. The ICHRA / QSEHRA people say "yes! you can offer either with a group dental plan! no problem!" Then some people say NO! A group dental plan is considered a GROUP health plan.

Just polling here.... can a group offer a QSEHRA / ICHRA ONLY for health insurance, but then have a group plan for dental / vision? There's folks out there that are saying, "no, because the dental is considered a group health plan... you cannot combine it with a QSEHRA and you cannot offer the medical insurance ICHRA with the traditional group plan dental". I disagree, but figure I should poll it here.

An employer wants to pay for all the participant related fees, so that no fees are taken from employee account balances. However, they do NOT want to pay for the participant fees once the employee leaves employment and becomes a former employee. If the employee fails to roll out the 401k account balance, the fees will be taken from their account. Anyone see any issues with this? Is there guidance / best practices around this?

When starting a new plan, must eligibility be waived for ALL employees? Or can we say "eligibility is waived for ALL full time employees"? However full time is defined.

Thanks!

Couldn't find a direct answer on this: Company has a 3 year cliff vesting schedule. Employee has been working at the company for 5 years. Then, finally decides to enroll into the 401K... but he leaves 9 months later. Is he fully vested? I think yes, because he has more than 3 full years of service... but wanted to get confirmation. Thanks!

So company XYZ is slowing going through bankruptcy / asset sales while ramping down their operations. The last employee enrolled in the health plan was laid off. There's still about 4 people there, and the doors / wind down might be another 4 to 6 months. Is the company required to offer cobra to the last participant? No one else took cobra. Since the plan has no participants... Its done, right? There's no health plan for the last employee to enroll into. So why even send out the cobra letter. If he accepts... He has no plan to enroll into.

For a stand alone vision plan... do they require COBRA notices to be sent? Let's assume no other benefits are being offered. Just vision insurance, that's it.

Great, thanks folks!

The look back period is undesirable because the stability period is undesirable. Now back to the question at hand: are the "units" in measuring the 95% safe harbor based on people, months, years, etc.?

So how is the 95% threshold calculated? So lets say that an employer fails to offer coverage to an employee for one month... i.e. they forget to offer coverage to a part time employee who becomes full time (due to an accident like scheduling too much overtime)... for a month. But only one month, because that employee was an "accidental full timer" in that they were a part time employee who worked more than 30 hours a week for one month due to too that employee being scheduled a bit too much overtime (or they stay late to do extra work when it was busy). Then a few months later, that employee becomes full time officially and enrolls in benefits. For this employee, was there a "offer of coverage"? Or is there NOT an offer of coverage because one month was missed?

Enter 1A IF they lost coverage and offer of COBRA was made because there was a reduction of hours... i.e. the employee still works for the employer. 1H if they are eligible for COBRA because they no longer work for the employer. 2A is pretty much always right.