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Exclude from definition of compensation the amount of any health coverage "buybacks"?


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If a client agrees to pay employees the cost that would have been incurred under a health insurance plan, had the employee elected to be covered by the employer, can that compensation be excluded from compensation for purposes of benefit accruals? I know the definition of compensation can be anything, as long as not discriminatory, but is this something that has been seen by other people?

I don't see any direct references in the plan document to such a provision.

Thanks

Austin Powers, CPA, QPA, ERPA

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