mming Posted 8 hours ago Posted 8 hours ago I've been finding contradictory info about whether or not such a notice is needed in my situation. An employee's date of entry was 1/1/26, but he was not informed that he could start deferring at that time. The employee has yet to complain to the employer about this - it was the employer who caught this error. The employee will be permitted to begin deferring with the first payroll period ending after 4/1/26. This should suffice for reducing the QNEC for the MDO to 0%. The plan does not have any autoenrollment features. Some sources say an MDO notice is still needed, some say it is not. I'm leaning more to the 'not needed' side, especially since the employee has not brought up the discrepancy - is this the way to go? Any help is appreciated.
John Feldt ERPA CPC QPA Posted 7 hours ago Posted 7 hours ago To allow a $0 correction, then the employer should provide the 45-day special notice after the correction begins. If the employer wants to give the 50% QNEC as part of the correction, then no notice is necessary. Look at Rev Proc 2021-30. mming 1
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