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We are setting up Auto Enrollment (4%) plan with Auto Escalation (1% annually up to 10%). When we looked at plan demographics we noticed that close to 40% of participants have elected flat dollar deferral elections instead of percentages. How would administrator auto escalate someone with flat dollar deferral election? Here are a few options we have considered. Divide pay period deferrals by the pay period comp and increase the flat dollar amount by calculated 1% if needed. This approach would potentially hurt folks with variable comp through the year, who want to ensure max deferral (402g limit) and not losing any match (match is calculated with per pay period comp). Exclude anyone who has elected flat dollar deferrals from Auto Escalation. Wondering if that would be considered definitely determinable in accordance with Regulation §1.401-1(b)(1)(ii) and uniform for EACA rules. Currently Top choice if prior sentence holds. Only apply Auto Escalation for participants who have not made any affirmative elections. However, that would only limit this entire plan provision to the future new hires, who never make elections. I would like to hear your thoughts and comments. Are there any other approaches you have seen that you would like to share? Thanks!
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Does the ACA require ANNUAL notification or just the first time a participant enrolls? The IRS brochure mentions that an EACA is similar to the ACA plan but has specific notice requirements. It does not specifically say that the ACA requires annual notification. Any confirmation is greatly appreciated!
