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Showing results for tags 'tiered match non safe harbor plan'.
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A plan has a tiered match formula. Each participant is eligible for one of the tiers (30%, 40%, 50%, or 75%). We understand we have to do a Benefits, Rights, and Features coverage test on each tier of match. Our understanding is that anyone who is benefiting at the same or greater level of match as the tier being tested, is deemed to be benefiting in that tier (i.e. if you get a 50% match, you’re considered benefiting in the tests for the 30%, 40%, and 50% tiers). In this plan, only the 30% tier passes. As would be expected, the 75% tier fails the worst. We are going to bump up an additional 17 participants from their current level of match to 75% to pass coverage. We believe that these 17 participants, who are now benefiting at the 75% level, should be considered as benefiting in all the lower tiers, which would make those tiers pass as well. However, the provider doing their BRF testing believes that different participants must be used to make each tier pass; i.e. even if someone was bumped up from 30% to 75%, you would still not consider them benefiting in the 40% and 50% tiers. What do you think? Can you find anything in the regs (or elsewhere) that addresses this situation?
