Message Boards Digest

March 15, 2022

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

Renee H created a topic in 401(k) Plans

Assets from Plan's Suspense Account Inadvertently Transferred to Employer

"One of my clients inadvertently moved money from the suspense account to the employer operating account instead of reallocating to participants in 2021. Are they now subject to the excise tax, or can this be self-corrected by moving the funds back to the participants' profit sharing accounts? If they must pay the excise tax, what is the percentage of the tax?"

1 reply so far   |    Click Here to Add a Reply

EB created a topic in Health Savings Accounts (HSAs)

Your Experience with HRA Substantiation Audits?

"Looking for experiences with HRA substantiation audits. Specifically, I have plans that suspend HRA debit cards where participants fail to send requested substantiation, send 1099s for unsubstantiated claims, and after 1099s issued 'turn on' HRA debit cards and let participants use again. Does this violate substantiation rules by creating systematic failure?"

1 reply so far   |    Click Here to Add a Reply

52626 created a topic in 401(k) Plans

Coverage Testing When No Wages Paid During Plan Year

"Plan has 450 employees that are only paid when called to a job site. During 2021 these employees were not paid W-2 wages because there was no job site work. The plan has 90 day service requirement.

The recordkeeper is assuming these employees are all non-excludable for 410(b) testing. Recordkeeper stated 'employees with zero compensation are included in the number of non-excludable employees but are not benefiting. They are considered as not benefiting because they had no compensation and thus did not have the opportunity to defer into the plan or receive contributions.' As a result of including this group in the 410(b) test, the coverage test fails.

If an employee has no wages, why are they included in the coverage test? Assuming they have to be included in the coverage test, how would you correct the failed coverage test? There is no compensation to calculate a QNEC or match. Not sure how to proceed. One thought: show them as terminated as of 12/31/2020, then if they are called to a job site in 2022, treat them as a 'rehire'."

2 replies so far   |    Click Here to Add a Reply

Coleboy1 created a topic in 403(b) Plans, Accounts or Annuities

403(b) Plan Failed ACP Test

"I haven't worked on a 403(b) plan in about 20 years. This 403(b) plan failed its ACP test. Do the match refunds go back to the plan as forfeitures, or do they get refunded to the participants?"

1 reply so far   |    Click Here to Add a Reply

Here are the most recently posted jobs on, a service of BenefitsLink:

View job as Retirement Plan Administrator

Retirement Plan Administrator  View details

Financial Services Firm

View job as Retirement Plan Administrator

Retirement Plan Administrator  View details

Nicholas Pension Consultants
Remote / Rancho Cordova CA / Corona CA

View job as Regional Director

Regional Director  View details

Employee Benefits Security Administration [EBSA]
Remote / Pasadena CA

View job as Director, Office of Exemption Determinations

Director, Office of Exemption Determinations  View details

Employee Benefits Security Administration [EBSA]
Remote / Washington DC

View job as General Attorney - EXC

General Attorney - EXC  View details

Pension Benefit Guaranty Corporation [PBGC]
Remote / Washington DC

View job as Implementation Manager - Retirement Plans

Implementation Manager - Retirement Plans  View details

The Standard
Remote / Howell MI

►View More Jobs

►Post a Job

►Get Instant Job Alerts, Inc.
56 Creeksong Road
Whittier NC 28789
(407) 644-4146

Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager

Copyright 2022, Inc. All materials contained in this mailing are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.

Links to web sites other than and are offered as a service to our readers; we were not involved in their production and are not responsible for their content.

Unsubscribe | Privacy Policy