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Eligibility and Auto Enroll


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Posted

Would a plan be permitted to have immediate eligibility, but have a 6 month or 1 year wait for automatic enrollment to kick in? Would the answers differ if it were an EACA or QACA?

Thanks!

  • 1 year later...
Posted

Anybody have any thought on this? In attempting to automate the Automatic Contribution notices and implement the initial default contributions. Plans with immediate eligibility are giving me fits! If I could delay the automatic enrollment until the next quarter, life would be good!

Would a plan be permitted to have immediate eligibility, but have a 6 month or 1 year wait for automatic enrollment to kick in? Would the answers differ if it were an EACA or QACA?

Thanks!

Posted

The final regulations issued in February 2009 had some surprises. Immediate eligibility doesn't seem possible for a QACA. You must get notices to people with reasonable enough advance time for them to make election before the default election. However the default election has a specific latest date that is a function of when a paycheck is issued and when a notice is received. The default election must also provide for matching contribuitons on all eligible pay. Immediate eligibility doesn't seem possible unless you can deliver notices at a reasonable time before people even begin to work and accomodate their election right away also. Good luck

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