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Discrimination Testing


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Guest K Flett
Posted

If a controlled group of employers offers a cafeteria plan (premium only) to several of its divisions, is it possible to offer different health insurance (fully insured) packages to the different divisions AS LONG AS the discrimination testing passes? Or is it strictly prohibited?

Posted

It's not a problem if you can pass nondiscrimination. Of course trying to figure out the nondiscrimination rules can be a challenge. Personally, I'd just use a 410(b) coverage test approach comparing the HCEs and NHCEs in each separate plan (or each separate "component" plan). No, there isn't any guidance specifically allowing you to use such an approach -- but I don't see how the IRS could ever challenge it.

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