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?

Had a first time request today - an intended future client of a one-time compliance project has asked if we can accept a Purchase Order from them in lieu of our signed service agreement. Not even sure how to react...

Thanks kcbirm, our approach has been to minimize the hassle and costs of changing tpa, as long as they understand there may be a cost to restate if necessary, prior to the next restatement period. Alternate scenario - what if the prototype plan is coming from a bundled arrangement in which they used their own approved prototype doc, and the prior recordkeeper is asking to have the doc restated?

when taking over a plan with a volume submitter or prototype plan document, say that plan doc is up to date and there is no particular amendment or restatement necessary, at what point do you restate the plan under the following two scenarios: 1. prior tpa had their own determination letter 2. they used a provider document (ie datair, ftwilliam) with an Opinion Letter, but the new tpa uses a different plan document provider Immediately upon takeover, or at such time as some kind of amendment (required or optional) is necessary? Understood there are a variety of plan document provider scenarios.

dan.jock - mazel tov on your new business this year, may 2017 be more profitable... may I ask the following: Did you start on your own or did you have ee's to take with you? Did you see a need for a new TPA in your location, and if so what was the need? Do you find cpa's and advisors with no relationships, or how do you get them to try out a new relationship?

I agree 100% with all comments above and indeed this is what we practice. But it doesn't seem to be enough. I would pose the question - is what worked 25 years ago, and for much of the time since then, still the best approach today and moving forward? As such a longstanding established tpa, is it easy to understand the work environment and challenges of a relatively young practice? The market is certainly much more saturated today, but there is still room for growth for quality service tpa's. I believe the opportunities are not so much in creating relationships with advisors that don't already have one, because most of them do. But rather in getting them willing to create new relationships because existing relationships have led to substandard and complacent servicing in some, (not all), cases. Many of these competing firms excel not in service, but in relationship management. This is where our challenge lies-advisors know that some of their existing tpa relationships have room for improvement in quality, but: 1. they are afraid to damage such relationship, 2. they are simply lazy and hesitant to create a new one. So, our thought is - times have changed and we do believe it is no longer business as usual, we want to shake up the local market.

With the objective of increasing advisor relationships, we are thinking to offer the following type of promotion. Anyone done anything similar? $1,000 off first year tpa services for a new client which is the first client brought by a new advisor for retirement plan services to our firm

I have twice had to recreate everything from scratch. I did not enjoy it, but the up side is that it is actually quite educational to get at some of the basics again and to really make sure to have up to date documents and forms, etc. I might ask another question though for a new TPA Practice: What is the strongest argument to offer financial advisors as a reason to try you out when you are a new practice and do not already have an existing relationship?

@Susan S. - I am curious to know what direction you and your practice have taken since your original postings?

any updated thoughts on trends, if any, for those smaller companies that may not have a payroll provider, don't want one, but could use assistance with these forms?

Anyone familiar with EBIA's Advanced Cafeteria Plans and Benefits Conference? Seems rather expensive for a small business, but with valuable topics.