chuTzPA

I'm thinking time we move from using passwords to secure files to a web based secure file exchange system. Any recommendations for entry level data exchange (for instance so HR can upload their trust accounting rather than email or fax)? free?

Reviewing prior TPA contract, there is a 45-day notification requirement to terminate. What rights does TPA firm have to provide billable services in that time period when Plan does not want it?

Dental benefit is provided for management, under 100 persons. It is offered as a fully voluntary benefit for staff. So total covered persons are over 100. I'm trying to figure out if this makes it an ERISA covered benefit, among other things requiring a Form 5500 be filed.

Chaz - that is what spouse believes, and what I believe, but I'll have to do some additional research to see what kind of documentation to back it up exists, since this is likely not specified directly. I was curious first what a general consensus would be before putting that kind of time in.

Received an inquiry, have no idea how to respond: Person in question is the spouse of an employee who is a subscriber of an employer offered health insurance plan, so the insurance is held in the employee's name, but it is the spouse with the inquiry. The spouse has on file with the insurance provider to not provide PHI to the employee subscriber holding the policy. The spouse visited a doctor. The insurance company then sent a follow up letter to the subscriber regarding that visit by the spouse to confirm the visit (specific details of the visit apparently not provided). Spouse felt this was PHI, but upon checking in with the insurance company, spouse was informed that that is not considered PHI. spouse believes just providing the doctor information to the subscriber is. To be clear this question is about PHI, not the relationship between the employee subscriber and spouse.

thanks! question is actually whether it's okay that they are filing as a 'Single Employer Plan' rather than a 'Multiple Employer Plan'

PEO takes on the W-2 pay, benefits etc. for employees who work at multiple different companies. For Health & Welfare benefits, they file one 5500 as a Single Employer Plan. Is this possible?

Good idea re family members but alas there are none

Thinking about plan design. ER has one owner, 40's, minimizes pay. Would like to start up new plan and willing to increase self pay to allow for contributions. 401k, safe harbor are fine. But this approach does not mesh well with xtested design since ratios are too high to pass. pay too low for integrated formula to function too. thinking about other design considerations.

To follow up with some of the comments: The circumstance here is indeed two different data sets - the original employer source census files and the actual annual valuation files that are imported into the valuation software. The discrepancy is based on comparing the two full sets of data which was a reasonable task rather than a more complex verification that the employer's source data itself is indeed correct. That's why we are feeling it was a nuclear response. Don't know yet the final iqpa conclusions. They have threatened to put in Notes but we are yet to see.

to what extent do they attempt to declare these minor issues of such significance that it has to go into the financial statements?

but that's not how the auditors see it. they are recording it as a complete and total breakdown in data control measures.

Is it an industry trend for pension plan auditors to go nuclear and penalize a plan sponsor with all kinds of Notes for seemingly minor data discrepancies such as one participant's date of birth off by a year out of 400 total participants, or a gender being incorrect on 3 participants?

I'm wondering if there is any update about this?

What's the latest on the potential requirement for small medical plans to be required to file 5500 starting with plan year 2019?