Message Boards Digest

April 20, 2020

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

AlbanyConsultant created a topic in Distributions and Loans, Other than QDROs

Handling Fee Disclosure Prior to Implementing Plan Loans

"I've got a plan that wants to be nice and add loans until 9/23/20 as part of the CARES options. Loans were never offered in the plan before. The plan sponsor would like to pass the costs of the loans on to the participants. Functionally, do we add the loan provision dated 30 days from now, giving out the notice today that starts the fee disclosure clock? That feels wrong, if not from a legal standpoint, then certainly from a 'doing the right thing' standpoint (and I fully realize that sometimes the rules are written such that 'doing the right thing' is not as easy as it could be)."

4 replies   |    65 views   |    Add Reply

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shERPA created a topic in Distributions and Loans, Other than QDROs

COVID Distributions -- OK to Limit to Fully Vested Accounts?

"Normally for plan sponsors who want to provide for in-service distributions, I recommend restricting them to accounts that are fully vested only, just to eliminate a potential error in later determining vesting. What are people doing/seeing WRT CRDs? Suppose an employee has $50K in deferrals and $25K in match, 60% vested. Total vested benefits are $65,000. Limiting CRD to $50K from deferrals only or also allowing up to $15K from match?"

3 replies   |    59 views   |    Add Reply

tsrl01 created a topic in Cafeteria Plans

Health FSA -- Why Must Coverage End Upon Termination of Employment?

"Where in the regulations does it state that an individual's coverage must end in a Health FSA upon termination and therefore no expenses incurred after termination may be reimbursed (unless COBRA)? The definition of Period of Coverage does not provide that the Period of Coverage ends upon termination. And under the Uniform Coverage rule, amounts must be available during the entire Period of Coverage, but if one is on a LOA and doesn't make the required contributions, or terminates employment, I realize expenses incurred when not a participant aren't eligible expenses, but my brain is a not helping me find the specific regulation language/section and I'm drawing a blank."

3 replies   |    50 views   |    Add Reply

TxMike created a topic in Health Plans (Including ACA, COBRA, HIPAA)

PEO's Calculation of COBRA Rates

"I was co-employed by a PEO and know the combined employer/employee rates for Medical coverage because I have the contract between my former employer and the PEO. Therefore, when I received the Cobra notice, I was surprised that the Medical rate wasn't just 102% of the total cost of the medical plan (employer + employee). Is there something that I am missing that would allow the PEO to charge more than 102%?"

5 replies   |    54 views   |    Add Reply

hsctpa created a topic in 401(k) Plans

Safe Harbor Plan Mid Year Changes

"I have a client with a safe harbor nonelective contribution plan that wants to exclude Christmas bonuses from contributions for 2020. My first thought is that this is a "reduction" in the contribution and, as provided in Notice 2016-16, can be done as long as a notice is given. However, the SECURE Act made it so there is no notice required for the SHNE safe harbor plan. The more I read my research materials the more confused I become - is this mid-year change allowed? If so, does ADP apply? Is there a notice required?"

1 reply   |    34 views   |    Add Reply

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