Message Boards Digest

January 7, 2019

Here are the most recently added topics on the BenefitsLink Message Boards:

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Belgarath created a topic in Cafeteria Plans

HRA, FSA, and HSA at the Same Time?

If you follow the guidelines, you clearly can have any two out of the three at the same time. If your FSA is limited purpose, and your HRA is set up to only pay after reaching the deductible of $1,350/$2,700, is there any reason you can't have all three? IRS Publication 969 seems to indicate that you can -- says you can have one or more of the following. Mind you, I have no idea how this would work in practical terms, or whether there is any advantage to it. Perhaps there is -- if you meet the $1,350/$2,700 deductible, and then your other plan(s) kick in, you could theoretically contribute the maximum to the HSA?

From page 4 of Publication 969:

Other employee health plans. An employee covered by an HDHP and a health FSA or an HRA that pays or reimburses qualified medical expenses generally can't make contributions to an HSA. Health FSAs and HRAs are discussed later. However, an employee can make contributions to an HSA while covered under an HDHP and one or more of the following arrangements.

  • Limited-purpose health FSA or HRA. These arrangements can pay or reimburse the items listed earlier under Other health coverage except long-term care. Also, these arrangements can pay or reimburse preventive care expenses because they can be paid without having to satisfy the deductible.
  • Suspended HRA. Before the beginning of an HRA coverage period, you can elect to suspend the HRA. The HRA doesn't pay or reimburse, at any time, the medical expenses incurred during the suspension period except preventive care and items listed under Other health coverage. When the suspension period ends, you are no longer eligible to make contributions to an HSA.
  • Post-deductible health FSA or HRA. These arrangements don't pay or reimburse any medical expenses incurred before the minimum annual deductible amount is met. The deductible for these arrangements doesn't have to be the same as the deductible for the HDHP, but benefits may not be provided before the minimum annual deductible amount is met.
  • Retirement HRA. This arrangement pays or reimburses only those medical expenses incurred after retirement. After retirement you are no longer eligible to make contributions to an HSA.
Number of replies posted  0 replies      Number of times viewed  25 views      Add Reply

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BG5150 created a topic in 401(k) Plans

Still Enough Time to Amend 2019 Safe Harbor Plan to Exclude Class of Employees?

Can I amend a 2019 3% SH plan now to exclude a certain class of employees? Coverage not a problem. None of the current employees thusly situated are eligible for the plan at this time.
Number of replies posted  1 reply      Number of times viewed  47 views      Add Reply
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TPAexplorer created a topic in 401(k) Plans

Gateway Contribution Required for Terminated Participant with Fewer than 500 Hours?

Plan is a safe harbor 401k -- 3% SHPS + PS allocated based on new comp method. Each participant in his own group. Plan document says 1,000 hours is required for a PS allocation. A terminated participant worked less than 500 hours during the year. Can the terminated participant receive only the 3% SHPS, or must he receive at least the minimum gateway?
Number of replies posted  2 replies      Number of times viewed  68 views      Add Reply
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cme685 created a topic in Form 5500

5500 Newbie Has Question About Question 8a

Am doing a 5500-SF filing for a "one-participant" plan -- 2 sibling partners in a general partnership with 2 self-employed 401(k)s that use the EIN of the partnership. For question 8a on 5500-SF, is the employee contribution of up to $18,500 per person (in 2018) to 401k go to 8a(2) participants and the 20-25% go to employee amount go to 8a(1) employers.... or does IRS want "one-participant" plans to lump all 401k (employer and employee) contributions to 8a(2) participants because it is not a "single employer plan"?
Number of replies posted  6 replies      Number of times viewed  76 views      Add Reply
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jwmc1 created a topic in 401(k) Plans

401(k) Loan Question: Should I Repay One of My Two Loans?

I am looking at paying off the two 401K loans that I have, but I am concerned that if something comes up and I need to borrow again that I won't be able to access enough cash. I have been reading through information on this forum as well as other sites and I am not certain of the calculation formula when you have two loans. Here are the specifics: Total Vested Balance = $73,870 Loan 1 Balance = $10,508 Loan 2 Balance = $15,180 Prior to borrowing Loan #2, I paid a loan off on 2/23/18 with an outstanding balance of $17,679. Assuming that I payoff the two outstanding loans on 2/15/19 and wait until 3/15/19 to borrow again what would my loan availability be? My assumption is that it is about $34,000. Does that sound right?
Number of replies posted  9 replies      Number of times viewed  85 views      Add Reply
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Earl created a topic in 401(k) Plans

Can I File the 2017 Version of Form 5500-EZ Today?

For a continuing calendar year plan, as of today(1/6/2019), can I file a 2017 5500-EZ, or am I required to wait until the IRS releases the 2018 version of the form?
Number of replies posted  4 replies      Number of times viewed  43 views      Add Reply
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B21 created a topic in Distributions and Loans, Other than QDROs

Use IRA Rollover to Avoid Tax Consequences of a Loan Offset?

If Company A acquires Company B in an asset sale where Company B maintains a 401k plan which Company A does not take over as part of the asset purchase, is it permissible for a former employee of Company B -- who had an outstanding 401k loan balance as of the date of purchase, which will be offset -- to obtain a loan from his new Company A 401k account & then roll over the amount of the Company B 401k loan offset to an IRA within the permitted deadline (i.e., the due date for filing his personal tax return)? Company A does not accept rollovers of participant loans. I'm thinking this would be allowed because the requirement of a rollover of a loan offset is that the employee must come up with outside funds to be deposited to an IRA or qualified plan to cover the offset amount.
Number of replies posted  1 reply      Number of times viewed  28 views      Add Reply, Inc.
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