dashab
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I agree.
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A wrap plan bundles all benefits into one. If any one benefit provided under the plan exceeds 100 lives, all benefits will need to be reported for the year on the Form 5500.
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Test
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If this coverage runs through cafeteria, the employer needs to analyze the situation based on whether the removal of the dependent is a permissible election changes under section 1.125-4. Not wanting to pay for coverage is not a permissible change under the cafeteria rules, so the employee would have to wait until the next open enrollment to make the change.
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A small church would like a self-employed minister to participate in its 403(b)(7) plan. The self-employed minister would be able to make salary reduction contributions to the plan as well as receive employer contributions. Everything that I have read seems to say that a self-employed minister is only eligible to participate in a section 403(b) plan of his or her denomination, and that the 403(b) plan has to be a retirement income account. Is that correct? Or can a self-employed minister participate in a 403(b)(9) or a 403(b)(7) plan established by his church and not by his denomination? I am mostly relying on 414(e)(5), so any other citations would be greatly appreciated.
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We have an employer that offers various insured benefits through their wrap cafeteria plan. Because the benefits are with different insurance carriers, the contract years are different. Because of the different contract years, the employer has different open enrollment periods for the various benefits it offers through the wrap cafeteria plan. So, for example, to enroll in medical insurance coverage, the open enrollment period begins in July for enrollments that take effect in September. For dental insurance coverage, the open enrollment is in May for enrollments that take effect in July. Does anyone know if the different open enrollment periods for benefits that comprise one plan are permitted under the cafeteria regulations? I have not yet found anything in the cafeteria regulations prohibiting this practice. Thanks for your help.