PBGC re Speech Therapist

[Cynchbeast]

We have a plan sponsored by a licensed speech therapist.  I am told she has a PhD but is not a medical doctor or psychiatrist.  Would this be considered a professional service organization and exempt from PBGC, or would this be subject to PBGC?

[david rigby]

Recent update to the PBGC website, discussing small professional employers:

https://www.pbgc.gov/prac/other-guidance/insurance-coverage

BTW, is this person a member of any professional associations?  Perhaps she can inquire if others have a similar experience.

[CuseFan]

In these gray areas we are providing clients with the PBGC criteria and asking them to either make their own determination (who knows their business better?) or to request a determination of coverage from PBGC. However, if there isn't an existing DBP, then PBGC won't rule, and if the question of coverage is one of the decision criteria in whether or not to adopt a plan, potential sponsors and their providers are left making educated guesses.

If you're looking for an educated guess here, my opinion is that a licensed speech therapist would be professional services.