PhilB

No, it is representative and made up of administrative exempt, non-exempt and factory employees.

Yes, we will apply the imputed income to the employee's earnings. But can we offer the coverage to only one segment of the employee population without discriminating against the other? I am aware of no such rule that would prevent us from doing this at this time but want to double check.

My company has been reviewing the self-funded medical plan design for our expatriate group (both U.S. expats and TCNs) and are researching whether our current plan is "typical" of expatriate plans, particularly the deductibles. We are interested in the type of plan designs offered by other companies. In particular, we are wondering if our deductible and out-of-pocket amounts create inequalities among our expatriate group due to cost differences around the world. We offer one indemnity plan that provides coverage for doctors' office visits, diagnostic lab and x-ray services, hospital expenses, surgery and anesthesia charges, prescription drugs, durable medical equipment, physical and occupational therapy, and psychiatric care. All charges are subject to an annual deductible ($200 Individual, $500 family). Once the deductible is satisfied, we pay 80% of the allowable medical expenses. The annual out of pocket maximum is $1,500 per person. The plan provides a yearly maximum of $350,000 per person and a lifetime maximum of $1,000,000 per person. I'd be interested in any comments or experiences you've had in developing and administering a plan for expatriate employees and the general plan design offered. This tends to be a highly vocal employee group, so we want to tread carefully in recommending changes! Thanks in advance for any replies.

My company sponsors a cafeteria plan that covers several subsidiary companies and employee groups under one medical plan design. We are considering offering domestic partner benefits to same sex couples, but are thinking of rolling it out first to only one of the business units (a subsidiary) as a "test case.” Are there any discrimination issues we could conflict with in offering DP benefits to one subsidiary business unit vs. another when both are covered under the same cafeteria plan?

I'm trying to research the prevalence of Pre-X clauses in Disability plans. Those of you who are consultants, can you shed any light on current trends? Any replies appreciated!

Is anyone aware of any reliable studies or information that examines the overall cost impact (if any) of adding coverage for domestic partners? Any info appreciated.

This has probably been covered before but I couldn't find it. Our benefit plan has a 30 day notification requirement for status changes. Our plan operates on a calendar year basis. Our employee has a support agreement (Dated 1/03) requiring her ex-spouse to cover their child and states that father must provide proof of this coverage, but he has not done so until now. She claims to have attempted to get proof for 9 months by email, letters, and even involved her attorney. She now has a copy of the insurance card that states the child was enrolled 1/15/03 under the father's plan. Now she wants to drop coverage for her son retroactive to January (and get a refund of premiums paid). I can't find any discussion of time limits in the regs, probably since this is an optional provision left up to the plan administrator. Is it permissible to 1.) allow a retroactive change in these circumstances since she just received proof of this coverage after months of trying; OR 2.) allow a prospective change from the date she received proof of coverage; OR 3.) She's stuck until 2004? Any opinions or citations appreciated!

This was actually stated on a message sent out by SAP to all client users. We have attempted to get them to cite chapter and verse for their assertion that when the employee is disabled, the amount of coverage that goes toward the calculation of imputed income is zero for the period of disability. No luck so far. However I did review publication 15-B and agree there is no exception for retired employees.

This has probably been covered before but I couldn't find it. Our benefit plan has a 30 day notification requirement for status changes. Our plan operates on a calendar year basis. Our employee has a support agreement (Dated 1/03) requiring her ex-spouse to cover their child and states that father must provide proof of this coverage, but he has not done so until now. She claims to have attempted to get proof for 9 months by email, letters, and even involved her attorney. She now has a copy of the insurance card that states the child was enrolled 1/15/03 under the father's plan. Now she wants to drop coverage for her son retroactive to January (and get a refund of premiums paid). I can't find any discussion of time limits in the regs, probably since this is an optional provision left up to the plan administrator. Is it permissible to 1.) allow a retroactive change in these circumstances since she just received proof of this coverage after months of trying; OR 2.) allow a prospective change from the date she received proof of coverage; OR 3.) She's stuck until 2004? Any opinions or citations appreciated!

Scenario: An employee is enrolled in a GTLI Plan which covers the employee only. Usually the amount of excess coverage over $50,000 gives rise to imputed income which needs to be added to taxable income. I have read, but been unable to verify, that when the employee is disabled, the amount of coverage that goes toward the calculation of imputed income is zero for the period of disability. I have also read that the value of the excess over $50,000 of GTLI coverage is not taxable to a retired or terminated employee. The reference led to another section of the reg. specifically 1.79(b)(2), which discusses the exception to the rule of inclusion. Unfortunately, this discussion does not pertain to the reporting of GTLI by the employer, but rather the requirements an EMPLOYEE must undertake to delete the added income when filing his personal income tax return. My question is whether disability is an exception to the application of imputed income and whether there is a qualification on the disability, such as it must be total disability. Any reference source would be appreciated. Thanks.

Does anyone have experience with or work with a good plan document software package that an employer can use in-house (as opposed to outsourcing to a consultant)? I have been looking at the software packages offered by SunGuard Corbel but am interested in examining alternatives to compare against. My primary interest is in H&W master plan documents as opposed to SPD software, though I would certainly be interested in combination packages. Any response appreciated!

Anyone from this message board attending either of these events? EBIA is sponsoring the Advanced Cafeteria Plan Seminar in Seattle in July and ISCEBS is sponsoring the Symposium in Phoenix in September. Just interested in networking a bit if anyone will be attending. Thanks!

Does a change in an employee's spouse's work schecule (FT to PT) qualify as a status change such that the employee can now enroll mid year in the DCSA? The spouse was NOT in a DCSA through her employer and is not going to PT status due to school, health, or to search for another job. In fact, the stated reason is so the spouse can spend more time with her children. Nevertheless, the employee now wants to use this event as a reason to join the DCSA. The regulations I could find on this topic through EBIA, though not exhaustive, indicate that a change could be allowed to an existing account if the change in a spouse's work schedule necessitates a change in outside child care required. Again, this is not the case in this situation. I have not found anything that would seem to allow the employee to enroll in the DCSA when his spouse moves from a FT to PT status. Any opinions?

Deductions are not addressed in our Plan Docs or SPDs, other than to state who contributes to the plans and whther the deduction is pre-tax. So it does not appear we would be limited in that sense.

Impose an additional "Working Spouse" premium for employees who are married to a spouse that works and is eligible for coverage under their own employer. The additional premium is contingent upon the availability of coverage under the spouses employer, not whether they actually elect the other coverage. If they are eligible and have the other coverage available, then your employee is subject to the additional premium. Otherwise, require proof from the other employer that the spouse is not eligible for the coverage. This is what we do at my company.