Scott A. Davis

Would you agree that HCE and Key Employee status do not factor into Form 5500 filing for welfare plans, even 401(k) and other Pension Plans? Thanks, SAD

Use cash and dividend distributions, keeping your taxable income lower for reportable income until Medicare Eligible, to qualify for a larger ACA Premum Subsidy and possible Cost Share Reduction for ACA Marketplace coverage. Great review Brian.

acm_acm, Brian is correct, Plan Sponsor/Employer is responsible for the ICHRA PCORI Fee. Even Premium Only ICHRA per the IRS. If you need the link I can send it.

Good catch MRestum - Only mandatory employer contributions, mandatory employee contributions, and mandatory contributions of accumulated leave are made to Plan. The Plan provides that “mandatory employee contributions (i.e. mandatory salary reduction contributions and mandatory contributions of accumulated sick leave, vacation, and severance) which are not actually or constructively received by the Participant will be considered Employer Contributions for purposes of the Plan.” The Plan also provides that “no contributions other than Employer Contributions are required nor will they be accepted.” Contributions are made during an employee’s active employment with Taxpayer.

Thanks Christine and Luke, agreed Group GAP is a fully insured HRA with many carriers.

Thanks Brian,

Is a Plan Sponsor offering only Group MEC coverage to an eligible ICHRA Class of employees, also allowed to offer an ICHRA to that same Class of employees, since Group MEC is not Traditional Group Health Coverage (MVP), (only MEC), nor an Excepted Benefit under ICHRA Rules? Same for offering the same ICHRA Class of employees both ICHRA and Group GAP coverage which covers a stated $ benefit amount of Deductible and Coinsurance? Thanks, as I have been asked both, but can not find a definitive answer.