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Posted

We're reviewing our procedures for a closed MEP (for a PEO), and we're looking to see what the adopting employers are REQUIRED to get versus what it would be USEFUL for them to get.  Not in terms of legal notices, but all the admin work.

Examples:
Top heavy test results - send.
Full 401a4 detail... not sent to the individual adopters.  No real good reason.

So, yeah, like that.  Is it just more sensible to treat this is X number of standalone plans and send them all the testing, etc. applicable to their population/'silo' portion of the plan?  What are others doing?

Thanks.

Posted

"Required" by what?  Your service agreement may say something about what you will do for the client, so that'll be required.  For IRS purposes, i don't think there is a requirement to have a report on testing.  The requirement is that you pass all tests.  Passing is "required", reports are not "required".    Of course not passing is bad and correcting is good and way easier if corrections are made within certain windows that you'll only know if you do the test.  So the TPA industry is built upon performing and providing reports as part of the "policies and procedures" the Sponsor has in place.

I have seen each unrelated employer treated as a single employer for valuation/reporting purposes and complete report/valuation packages sent to the whom the TPA was asked to send it.  That was sometimes the Plan Sponsor (they got all participating employer reports and did what the wished with them) and sometimes the adopting employer level.

Clear communication of expectations reduced to clear service agreements (TPA to PEO, PEO to Participating employers) lead to what's required, which to my mind should align with what's useful.

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