Any comments appreciated as to whether pharmacy tourism works.

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Appreciate any insight on the merits of in-house claims administration vs. using outsourcing to a TPA vs. using a medical vendor for larger (Fortune 500 size) corporations.

I was hoping someone could explain how the Most Valuable Allocation Rate is developed when cross testing a cash balance plan. For the Normal Allocation Rate, I projected the cash balance to retirement age using the interest crediting rate of 2.80% (30-yr treasury rate) and then converted to a life annuity using the Plan's Actuarial Equivalence (also 2.80%, and the 2017 applicable mortality table -- post-retirement only). I then converted this benefit accrual to a lump sum using the standard interest and mortality table (8.50% and UP1984) and discounted it to their current age at 8.50%. This amount is divided by testing compensation to determine the Normal Equivalent Allocation Rate. Now, because this plan pays immediate lumps sums, I am getting conflicting directions on how the most valuable equivalent allocation rate should be determined.

I got divorced in 2007 -- at that time, my ex-wife was awarded 50% of my 401K. A QDRO was done stating this. She never took the money out -- the Plan never divided the money, I even got a loan from the 401k twice (which I should not have been able to do before they split the money). The loans have been paid back. Fast forward to 2017, she is wanting the money and is unfortunately, not using a QDRO lawyer, just a divorce lawyer, so she keeps writing the Order wrong to the Plan Administrators. The first time the Plan Administrators told her the Order must clearly specify whether loans are included in the participant's account balance prior to any calculations and to submit an amended draft or court-filed QDRO. The lawyer answered that wrong. Second time, they asked for historical statements issued by the previous plan administrators and provide an amended QDRO containing a specified dollar amount to be awarded. Unfortunately, that was in 2000 and the previous plan says they don't have that info. Her answer is to sue me -- a Motion to Modify Postdivorce Domestic Relations Order. Anybody have an idea how to respond to this? Any thoughts would be appreciated.

As I read Rev. Rul. 2012-3, if a defined contribution plan offers a single life annuity or a QJSA as the default form of distribution in the absence of a participant election, and also offers a lump sum, spousal consent is not required if the participant elects the lump sum prior to the participant's annuity starting date. Assume the plan has no annuity investments, and thus, e.g., Situation 2 in Rev. Rul. 2012-3 would not apply.

When it comes to plan terminations, we have always obtained all benefit elections and then instructed the trustee to distribute benefits all at one time. Is this really required? For example, we handle a 10 participant non-covered traditional DB plan that terminated November 30. Is there any problem distributing the benefits to one of the two 50% shareholders of the plan sponsor now and all remaining participants 6 months from now? All participants other than the one remaining 50% shareholder would receive their full benefits (including PVABs determined up to the distribution date). The one remaining shareholder will end up waiving about 10% of his benefit. Thanks.

Is there any legal (or other) significance behind the 5% contributor disclosure (for employers contributing to multiemployer plans)? Or is that just what's required by FASB?