"So memory is that you couldn't have both the carryover(rollover) AND a grace period with regard to a health FSA. Then Covid/CAA/etc. came along, and I'm not sure now whether the temporary allowance of rollover if you also had carryover expired, or is it permanent? Or maybe I'm completely off-base anyway... Thanks."

"We have a safe harbor 401(k) plan that uses the top-heavy exemption due to the fact that the only employer contributions to the plan are safe harbor contribution. They are merging with a non-safe harbor plan January 1, 2023, that is going to be deemed (more than likely) top heavy on December 31, 2022. The question is if the top-heavy contribution is going to be made to the surviving safe harbor plan sometime in 2023, does the safe harbor plan loose it's top-heavy testing exemption? Both plans are calendar year. I am understanding because the non-safe harbor plan is considered terminated, they should make the final top-heavy contribution. Any comments are greatly appreciated."

"I feel this is a very basic question, but still want a more professional explanation: To become catch up eligible, does the participants need to max out the 402g limit? My understand is: to be eligible for catch up contribution, the participants need to meet the age requirement and max out the 402g limit. However, SPD indicated if you reach age 50 during the year, you can contribute catch up contribution anytime (people interpret this as no requirement for max out 402g because if the contribution is by paycheck, most employee won't max out at the 1st paycheck). This caused a lot of employees able to select a% for both contribution at 1st day of the calendar year they become age 50, and they may not max out the 402g limit at the year end. Plan is a calendar plan and catch up is not matched."