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Found 6 results

  1. I'm working with an employer who has employees who do not work over the summer. They will continue to be covered under the employer's group health insurance plan but must pay for their portion of the premiums which would otherwise come out of their paycheck. We are concerned about what happens if the employee does not pay their portion of the premiums. My understanding is that there is a 30 day grace period under the ACA and that if the policy is canceled for non-payment, the employee is not eligible to re-enroll until the next open enrollment period. My questions are: 1) Is it correct that there is a 30 day grace period under the ACA? 2) If so, do you know what statute or regulation requires it? 3) Can state laws require a longer grace period (I believe they can for individual plans but can't find any information on group plans)? 4) Is it correct that they cannot re-enroll until the next open enrollment? Any cite for that? Thank you so much for any help you can give me.
  2. I am working with an new administrator on moving plan assets and the blackout notice they provided to the affected participants does not specifically use the word "blackout". Rather, it uses the language "No Transaction Period" interchanged where the word "blackout" would be generally used. The notice contains all the other necessary language and dates, but I've just never seen a notice that doesn't use the word "blackout" to describe the period. Is this allowed under IRS & DOL regulations? Thanks
  3. Who is considered an "interested person" for purposes of the VFCP notice under PTE 2002-51 (as amended in 2006)? Has anyone taken the position that (or asked the DOL whether) it is limited to only those participants and beneficiaries affected by the failure, or must the notice be given to all participants/beneficiaries in the plan (like the determination letter NIP)? I could not find any guidance on this, so just wondering about other practitioner's thoughts/experiences.
  4. I’m interested in learning more about how Plans account for fee disclosure change notices during their transition to a new provider/recordkeeper. As transitions can take a few months to work through Plan details, determine new fees (plan level and individual fees), and finalize how the investments will transfer; it seems having the change notice to participants 30 days prior to their first opportunity to choose investments could be tough. Does anyone have experience with these notices and how you've handled it in the past, specifically when the assets are “mapping” to new investments and the blackout begins about a week prior to the effective date. In this scenario participants wouldn’t have access to their accounts until after the blackout ended.
  5. We have a non-safe harbor 401k. Employer match is discretionary. We want to change the match formula this year. My questions are: 1) Are we required to notify the employees? 2) Is there a deadline for notifying employees? For example, the notice must be sent 30 days before beginning of the year, 1/1/2015. 3) Can we change the formula now effective the beginning of the year, 1/1/2015? Thanks for your help.
  6. Last year, my company burned through their 100+ employee grace period with the SIMPLE IRA. This year, around January 10th, (5 days before our first paycheck of the year), we were informed that the company could no longer offer the SIMPLE program. This sounds a lot like the employer is breaking several rules. 1. Operating a SIMPLE IRA with over 100+ employees (as of January 9th, of this year, employees knew nothing of the situation) 2. Terminating the SIMPLE plan without giving employees 60 days notice 3. Terminating the SIMPLE plan mid year My employer claims to be searching for a 401k program, and hopes to have one available within the next few months. Several employees are considering leaving this employer and would like to know if anyone has thoughts / ideas as to what may be done to handle this situation from the employee's perspective.
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