FT William Plan Docs - Eligibility Expressed in Days

We use FT Williams for plan  documents (new to us) and we have a client who uses 60 days of service and not two months.  We cannot find a good way to fit that in the document.  IF we use the "Other" field, FT automatically includes the failsafe eligibiility language.  It also does not give us the opportunity to elect Elapsed Time for eligibility.  It seems as though the only way of electing elapsed time is to use something already hardcoded for months.

And this employer has had the 60 days eligibility for 1,000+ employees for years so, no, they will not change  to 2 months 🤣

Any suggestions appreciated!

Talk to FTW?

We're asking them too 👍

2 hours ago, austin3515 said:

It also does not give us the opportunity to elect Elapsed Time for eligibility.

Quote

Other - The service requirements provided must comply with Code section 410(a), be definitely determinable and may not be specified in a manner that is subject to Employer discretion. Hours of service failsafe applies: the service requirement shall be deemed met no later than the end of an Eligibility Computation Period during which the Eligible Employee completes 1,000 Hours of Service; provided, that the individual is an Eligible Employee on the applicable entry date.

Why not though?  It doesn't say that you can't use ET, it says the HOS failsafe applies.   If your "other" is 60 days elapsed time, would the failsafe ever trigger?

My guess is that the response from FTW support will be that" it can be interpreted to allow elapsed time".  I look forward to hearing what they say, though.

We would use "specified months - elapsed time", but I understand that isn't an option in your case. 

They said too bad so sad edit the spd in Word(non starter because we will never be able to edit every time we do a new amendment). Very disappointing. Tons of clients use days instead of months.

No, the fail safe would never apply but the client is annoyed because the sentence makes no sense in the context. It’s literally the next sentence after “you’re eligible after 60 days.”
 

Super disappointing. 

@austin3515 So you can use it, but the issue is the language that shows up in SPD, annual notice, etc.

Yea that is disappointing. 

This may be another non starter, but I bet they can do a custom dev project to remove the failsaife language from the notices and SPD.  We wanted custom language in the SAR and didnt want to have to edit each one, so we had them create a different SAR just for us. We did a couple of other ones too, saved a ton of time. There would be a cost associated, but if its common enough it may be worth it.  Talk to Holly if you want to spec out a custom project, not support.

I think I have a best possible solution.  Not perfect, but ok and certainly better than what I'm getting today.

In paragraph e. (which is ____months of elapsed time) we enter the following exactly:  “90 days of service –approximately 2 (two)”  

 Then the SPD and the AA both say “60 days of service – approximately 2 (two) months of service” and the failsafe eligibility language won’t display.

 I think that will work...  Like I said not perfect, but good enough.

6 minutes ago, austin3515 said:

I think I have a best possible solution.  Not perfect, but ok and certainly better than what I'm getting today.

In paragraph e. (which is ____months of elapsed time) we enter the following exactly:  “90 days of service –approximately 2 (two)”  

 Then the SPD and the AA both say “60 days of service – approximately 2 (two) months of service” and the failsafe eligibility language won’t display.

 I think that will work...  Like I said not perfect, but good enough.

Probably "60 days of service..." instead of "90 days of service..." would work better.

😇

uggh my bad.  I think you are referring to my lack of consistency.  It seems to be either 60 or 90 with the clients who are using this convention (or 30 of course).

In paragraph e. (which is ____months of elapsed time) we enter the following exactly:  “90 days of service –approximately 3 (three)”  

Then the SPD and the AA both say “90 days of service – approximately 3 (three) months of service” and the failsafe eligibility language won’t display.

Unfortunately the months of service field on their system is a drop down where you have to pick a number.  Our documents person came up with this though

1) Pick 3 months of service elapsed time for eligibility.

2) In the custom language addendum enter the following (paraphrasing, we are being more specific but hey trade secret!): For purposes of determining eligibility 3 months of service means 90 days of service.

3) In the SPD there is a custom language module where you can specify text that appears at the beginning of the Eligibility section before anything else ("Top").  In that custom language field you can type: "The term 3 months of service as used below shall mean 90 days of service."

Still clunky but better than the fail safe language which will confuse anyone who reads it (because the obvious assumption will be that it is there because it is relevant).

1 minute ago, austin3515 said:

Unfortunately the months of service field on their system is a drop down where you have to pick a number.  Our documents person came up with this though

1) Pick 3 months of service elapsed time for eligibility.

2) In the custom language addendum enter the following (paraphrasing, we are being more specific but hey trade secret!): For purposes of determining eligibility 3 months of service means 90 days of service.

3) In the SPD there is a custom language module where you can specify text that appears at the beginning of the Eligibility section before anything else ("Top").  In that custom language field you can type: "The term 3 months of service as used below shall mean 90 days of service."

Still clunky but better than the fail safe language which will confuse anyone who reads it (because the obvious assumption will be that it is there because it is relevant).

Just FYI, If you are using FTW for testing, it will use 3 months and you may need to do a lot of overrides for eligibility.  

its funny because we use Relius but we've always used the 3 months of service and not worried about the difference.  We're not calculating year end contriubtions for these plans. These are the larger plans that are doing pay-period match calculations, sans true-up.  That's a general rule of course, never say never.  If participant counts are off here and there that's not something I would worry about.