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Control Groups and Compliance Testing


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Posted

If a control group situation exists with multiple plans and multiple plan sponsors, must there be uniformity in plan design? Also, must you aggregate the plans for non-discrimination testing? I understand that the 410b test must include everyone from all of the companies as part of the denominator, but is there a situation where you are required to aggregate for testing?

Posted

If you aggregate for one (coverage or nondiscrim) you have to aggregate for the other.

I don't believe that uniformity is required as long as all of the Benefit, Rights, and Features pass nondiscrim. This could force some sort of uniformity, however.

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