Message Boards Digest

May 15, 2020

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

Christopher Wilson created a topic in 401(k) Plans

Safe Harbor Weighting for 401(k) Plan Contributions

"Can anyone provide me the IRC section for the 0.5000 safe harbor weighting for contributions?"

9 replies   |    88 views   |    Add Reply

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

Retiree Premium Reimbursement Program -- Constitutes an HRA?

"Say a mid-size employer has a written policy, or a series of individual agreements, that applies to executives (say VP or above) who retire with 10 years of service at age 55 or later. Once they retire, the employer will reimburse them up to a fixed dollar amount per month for the retired executive's personal payment of individual health insurance premiums. Reimbursement will last until Medicare eligibility. Substantiation is required. No other medical benefits are provided; just a capped premium reimbursement for a fixed amount of time. What, exactly, is this? An HRA or something less? For purposes of ACA market reforms and related guidance, it's called an 'employer payment plan,' and the guidance seems to draw a distinction between an HRA and an employer payment plan. (In any event, if limited to retirees only, it's not subject to the market reforms.) The guidance makes it clear that this arrangement is a 'group health plan,' but it's not exactly clear to me what that would require given the exemption from the market reforms and lack of penalties. Does this need an ERISA plan document, SPD, 5500 if covering 100+ participants? COBRA rights?"

0 replies   |    16 views   |    Add Reply

Catch22PGM created a topic in Form 5500

Participant Count in a Prevailing Wage Retirement Plan

"Client established a separate 401(a) plan just for prevailing wage contributions. They have a group of SCA employees who are the eligible participants. Out of 35 total SCA employees only 15 received contributions and have account balances. The other 20 had no excess after wages and other benefits so they received no prevailing wage contributions. For the Form 5500-SF, are the 20 who did not receive contributions considered participants? The compliance and 5500 software we use says yes and I guess it makes sense -- you don't have to receive a contribution to be a participant, you only need to satisfy the plan's eligibility requirements. The client is getting a large contract that will add more SCA employees and I want to be sure we don't push them into a 5500 audit for the 2021 plan year if it isn't necessary."

1 reply   |    26 views   |    Add Reply

TPApril created a topic in 401(k) Plans

Charging Fees to Participants for Changing TPA

"Plan Sponsor normally charges annual administrative fees to all plan participants. Client has changed TPAs. Can same plan sponsor charge the following fees to participants: [1] Plan Document restatement by new TPA when the restatement is not a required restatement but just from changing TPA; [2] 'Transfer fee' by old TPA for providing participant data to new TPA."

2 replies   |    52 views   |    Add Reply

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

Missing Participant Due Over $5,000

"Is there any way for the trustee of a 401(k) plan that is not terminating to legally roll over a large balance on behalf of a missing or unresponsive participant to an IRA?"

6 replies   |    53 views   |    Add Reply

Michael B. created a topic in 401(k) Plans

Terminate a Non-Calendar Year SIMPLE 401(k) Plan Mid-Year?

"Does anyone know if you can terminate a Non-calendar year SIMPLE 401(k) plan? Plan year is 7/1 thru 6/30. Employer wants to start a traditional 401(k) plan in the same calendar year. I know that for SIMPLE IRAs they always operate on a calendar year basis but I'm not sure about the SIMPLE 401(k)."

0 replies   |    19 views   |    Add Reply

Just Tri created a topic in Retirement Plans in General

Davis Bacon Plans Annualization

"Plan accepts Prevailing Wage contributions and provides that they can be used to offset Profit Sharing. PW contributions are 100% vested. Although the plan document allows for offset, it doesn't address if those amounts used for that offset can also be subject to the Profit Sharing vesting schedule. Does the plan document have to specifically allow for the application of a vesting schedule on those amounts that are used to offset PS? Can someone point me to a resource that discusses this in more detail?"

6 replies   |    37 views   |    Add Reply

nancy created a topic in 401(k) Plans

Life Insurance Policy at Normal Retirement Date

"I have a 401(k) plan with life insurance policies (ugh!, it was a takeover). One of the participants with a policy is terminated and is age 64. Is it correct that the plan sponsor needs to either distribute the policy to him at age 65 or convert the policy to cash? From what I read, if he were still working for the sponsor and not retired, the policy could stay in force."

3 replies   |    33 views   |    Add Reply

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