dseals

QACA Safe Harbor plan is switching eligibility, from 1 year of service, to 90 days of service, with quarterly entry dates. The company has 15-20 student interns who may work one semester, take off the next, then return later in the year. How would you go about counting the 90 days for employees who work sporadically? If an employee works 75 days during the course of the 2015 plan year but isn't employed on 12/31, do those days of service that were worked in 2015 roll over to 2016 or do we begin the count again, since the person termed prior to the plan year end without meeting the requirements?

The hire/rehire dates are all entered correctly but the program just sees that a participant has returned, assigns the original participation date, and declares they were in at BOY. So, what we now have is @ 50 participants who terminated in a prior year(s), then returned at some point during 2013 (none of them returned on 1-1-13), and the program throws them back into the BOY count based on the prior DOP.

We have a plan that is hovering around audit size. At 12/31/12 the plan had 115 participants, so it fell just under the first year audit size for 2013. On 1/1/13 the participant count grew to 160, but the question is, how do we base our count? The plan has no hours or service requirement and entry is on the date of hire. Since this is a health care placement group, we have many employees who work as fill-ins and are hired for a week or so, here and there, during the year. The problem is that if an employee became a participant and terminated during 2011, didn't work at all in 2012, then was hired to fill in for a week in November-2013, the program is counting that participant as a body on 1/1/13. I haven't been able to find any document that discusses how to handle rehires in this situation. Should the beginning of the year participant count be inflated for these "participants," even though they didn't physically get rehired until later in the year?

A large doctors group carved out >100 employees who were sold to a hospital group. These employees continue to work in the same capacity for the doctors group, and the hospital pays the doctors group to manage them. The hospital group offers full benefits, including a 403b plan - we don't have knowledge yet of whether or not the hospital group matches deferrals at this point. The doctors group has @ 80 remaining employees - all upper level management and doctors. They would like to max out the plan between Safe Harbor NEC and cross-tested profit sharing allocation (entity is a partnership). If the hospital does not offer an employer contribution, will the doctors group have to fund safe harbor and profit sharing for the group that is being leased back?