Message Boards Digest

June 23, 2022

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

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

ACA Reporting Form 1095-C -- W-2 Safe Harbor for Non-Calendar Year Plan?

"The instructions for completing Form 1095-C state that an employer can only use the W-2 Affordability Safe Harbor if it applies for the entire year. I assume this means calendar year (tax year) as that is the reporting period. Are the rules any different for a non-calendar year health plan?

For example, if the plan year is July 1 -- June 30 and premiums are 'affordable' Jananuary through June but increase on July 1 such that they are no longer affordable July through December, can the employer use the W-2 Safe Harbor code for only January through June? My interpretation is "no." It seems straight forward, but I'm getting pushback from an accounting firm and I'd like to make sure I haven't missed something."

1 reply so far   |    Click Here to Add a Reply

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pensionreview created a topic in Form 5500

How to Correct EIN on Form 5500-SF?

"What's the best method to use to correct an EIN on a Form 5500-SF that already has been filed? I don’t believe amending the 5500 to show the correct EIN in box 2b of Form 5500 would work because the correct EIN in box 2b would not be able to cross-reference the original Form 5500 that had been filed using a different and incorrect EIN."

1 reply so far   |    Click Here to Add a Reply created a topic in 457 Plans

Cash Outs of Accumulated Vacation Pay

"A tax-exempt employer allows all employees to accumulate unused vacation pay. Employees may cash out up to 25% of unused days in any calendar year. When the employer has extra staffing needs, it allows them to cash out the entire bank. When employees retire, they are cashed out.

The obvious 457(f) issue is the cash-out. At what point is this vested deferred compensation?

The annual vacation schedules are negotiated with a union -- 2 to 4 weeks, based on seniority. This is not just a special deal for executives, although they participate also.

I think this is a fairly common design, and I've seen little in the way of IRS guidance. Thoughts?"

1 reply so far   |    Click Here to Add a Reply

thepensionmaven created a topic in Retirement Plans in General

Excel Spreadsheet for Affiliated Service Group Testing?

"Does anyone know of an Excel spreadsheet for ASG determination?"

4 replies so far   |    Click Here to Add a Reply

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

414(m) Management Group as a Single Employer Plan -- or Is It a MEWA?

"Client maintains two companies. One is a professional service corporation (the 'PC'); the other provides management, back office and other services to the PC (the 'MC'). MC only provides services to the PC, no other clients. There is no cross ownership between the two companies, just a management services agreement.

MC and PC want to combine their employees for purposes of medical plan coverage. Is it a MEWA? Does the answer depend on whether they qualify as a management group under Code 414(m)? I found an old opinion letter that says that whether they are a management group or ASG is not determinative as to whether they can be treated as a single employer for purposes of determining if a MEWA exists, but that doesn't give me much comfort."

1 reply so far   |    Click Here to Add a Reply

Roxie99 created a topic in Cafeteria Plans

Qualified Event -- Exclusion of Abortion Services

"If an insurer decides to comply with applicable law so that, for example, the insurer decides to no longer provide abortion services, do you think that such a reduction in services would constitute a change in status so that a participant could make a change in election to another plan that provides such services?"

2 replies so far   |    Click Here to Add a Reply

MaryMcConnell created a topic in 401(k) Plans

Irrevocable Election to Opt Out of Plan Participation -- Minimum Coverage Test Fails

"I believe that a person who 'opts out' (via an irrevocable election) is not an excludable employee for purposes of the coverage test, and is treated as not benefiting.

There is only one NHCE in this particular plan, who signed an irrevocable election. (The individual would have been eligible otherwise.)

Coverage fails. Plan document allows us to bring in enough NHCEs to pass coverage. Can we give the opt-out person an allocation to pass coverage, despite the election?"

2 replies so far   |    Click Here to Add a Reply

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