TPApril

Situation: Current Plan Sponsor does not allow expenses after 12/31. Not interested in new $500 carryover law, but with this new ruling, will now consider extended spending period (instead of $500 carryover) effective only with 2014 plan year because of perceived extra admin with $500 carryover rule, especially applying it to 2013. I'm not seeing what the extra admin is for current or future years.

ok thanks, just thought i'd ask, trying to cut costs by not asking the actuary, but i see will have to ask the professional.

Pardon my lack of knowledge on the topic please. Without using pension software, is there a basic excel formula to come up with a rough estimate of the annual cost of a participant, by plugging in say projected retirement benefit, years to retirement, interest rate or other relevant parameters?

That is my working best solution, and was hoping someone else might think so.

If someone might refer me to someone who might be able to assist me with this question, I would greatly appreciate it.

I know this question is 2 years old, but I'd also like to know the answer. To me, I don't think there are guidelines for this, and the % experienced could certainly be much higher. I'm guessing it is that % that is used as a guideline for whether to provide the experienced or non-experienced information, and that only one or the other is provided, but I don't know. Another question I have is - what if the policy provides multiple types of benefits, and it turns out that pricing for one of the benefits is based on experienced-rating and for another benefit non-experienced. Would there be info provided for both sections of the Schedule A? Two Schedule A's for the same group?

Ever seen both items 9 and 10 filled out on the same 5500 and if so, any guidance on being allowed to do that? I know there is next to no guidance in the formal instructions. Apparently insurer uses one methodology on Health and Dental and the other on Vision, and thereby has no separate records of claims paid on Vision.

so to confirm, this new formula can be applied (somewhat retroactively) to current cal plan year 2013?

yes.

Following up on this thread - howbout a situation where the HCE-Owner wants only to contribute for her 1 staff and not for herself. Current formula is standard pro-rata. Can she amend for calendar plan yr 2013 so she is completely excluded, or must she treat as contributable compensation that what she has earned to date of amendment, and only exclude comp after plan change?

Interesting thread. I'm curious to know how it was ultimately resolved.

which brings me back to my original questions.

My understanding was that the 'wrap plan' document was required in order to file multiple welfare plans in one 5500. It can also help fulfill the ERISA plan document requirements which welfare benefit plan contract documents do not always satisfy. We use legal compliance tools for reference which detail these requirements and Im happy to have welfare plan discussion on this board which mostly focuses on retirement plans.

GBurns - In order to file multiple insurance companies in one 5500, a wrap plan document is required. There are many companies that do not have such documents and therefore file their benefits separately. I work in a small plan market where the issue of 100 employees is very common and whether a company is required to file is a big issue, which is the source of my inquiry. Here are a couple of examples of companies that file separately: 593472656, 650784737.

I wish I was as well travelled as you.

Bil - what do you see as potential inherent exposure to using approach 3 for the prior 2 years?

Association was sponsoring a large welfare plan (medical), or seemed to be sponsoring the plan, for multiple members, but only one member group had over 100 ees. No 5500 filed for 2010 and 2011. Since 2012, members now contract directly with medical insurance co. - Who ultimately bears responsibility for the two missed years? Association may be interested in filing missed 2 years but they are not interested in paying the $4000 penalty, even though they understand the potential penalties.

In this particular case there is no plan document, no SPD, and no Plan number since no 5500 ever filed. I would guess then proceed with getting plan document/spd requirements settled, and as you suggest, maintain both as separate plans so as not to have to file 5500's. General conclusion is that each separate medical carrier can be considered its own plan for erisa purposes, even though employees can only choose one or the other.

Any thoughts? 2 Medical plan carriers = 2 plans or 1 plan if employees choose one or the other?

Different, but related, situation: company has filed their medical 5500 for the past 2 years. They just determined that they should have been filing for those two years Life Insurance and Employee Assistance Program (we have already reviewed determination related to filing EAP plans). they would like to file 1 wrap plan in the past and moving forward. which option is the best approach for the past: 1. create new plan number and file all 3 together for the past 2 years. 2. create new plan number and file wrap plan for only the 2 missed in the past, and 2012, but moving forward bring in the medical, marking 2012 as the final year 3. amend the medical to include the other two as a wrap plan, thereby not paying dfvc fees (they acknowledge responsibility of dfvc fees, just looking for best approach)

morris - your post of a year ago is appreciated. Yes I get it now. 2 coments though: I stand by 2011 being the 1st filing when plan went over 100 1st in 2010. multiple carriers of same benefit - say company has 2 medical insurance options - each has 52 covered staff. Would this be considered 1 benefit then that files 1 5500 with 2 schedule A's? or dont have to worry and file?

Hard to imagine a Plan Sponsor being well informed and choosing not to apply. Plan in question is so basic, I'm thinking they should just move on to a prototype or volume submitter to reduce the issue of continually applying.

How common is it for a plan document preparer to not submit for a Determination Letter? Individually Designed Plan had a prior DL which expired and though IDP was restated timely, no DL was requested. What if the plan needed to file a VCP?

good point, especially considering the prospect of distributing it to the correct employees for each year.

What are your thoughts on providing one historical SAR which lists the premiums for each year all on one page?