Does Medicaid follow the same rules as Medicare in terms of "Secondary payer" rules? For example, if someone is under a group health plan, (more than 20 employees) also has an HRA, and is ELIGIBLE for Medicaid, and Medicaid pays a provider for something, the group health plan should pay first, then Medicaid? What happens if there is a deductible on the group health plan - let's say $1,000, and the provider charge for services is $800. The employee writes a check for $800, then is reimbursed from the HRA. Now Medicaid or Medicare pays the provider as well. Is the provider obligated to send $800 to Medicare/Medicaid, or does the provider send $800 back to the employer HRA? I really have no idea how these rules work. I believe the provider is required to bill the primary payer before billing Medicare. Then if the primary payer denies all or part of the claim, the provider bills Medicare. Can an HRA even pay you if you are covered by Medicare or Medicaid?

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If a 403b loan policy is amended to permit loans to terminated participants -- in distinction from allowing an active participant to take the loan and then continue loan payments after he terminates. Is there any downside to this? The loan policy provides for repayments via ACH so provided the terminated participant is able to set up the ACH deductions correctly and timely, I guess this is OK.

So, if a company is owned 100% by an ESOP, is there any exception to the excluded stock rule in 1563(c)(2)(A) that would allow (or require) this company to be considered part of a controlled group? It seems like the stock is initially attributed under 414(b), but then disregarded under 1563.

I'm single and have zero income so I haven't had to file a tax return for the last couple of years. If I take a small early withdrawal, say $5,000, from my 401k, would I need to file a tax return for an annual income of only $5,000? My rough calculations seem to show that between my exemption and standard deduction it would be a wash. But I thinking that because of the source of the income I might be required to file?

Can a nursing home 403(b) plan permit participants to make 15-year service catch-up contributions? I don't think they would be considered a home health service agency or health and welfare service agency. Could it be considered a hospital?

Client has a calendar year SH NE 401(k) plan. PS allocation conditions are 1,000 hours and last day. The client wants to amend the plan retroactively to 1/1/17 to remove the last day requirement since operationally that is what happened. Can we use an 11(g) amendment to accomplish this? If not, is there any other way to accomplish this?

Suppose the record keeper received employee deferral contribution through wire after the trade for the week was completed. And the record keeper waited the next trade to deposit the deferral contribution in to each employee deferral accounts. How should it be treated the days elapsed between employee deferral contribution received and deposited in to each employee deferral account for VFCP application and lost earnings purposes?