"My client just recieved a NMSN for an employee on May 30th and the date on the NMSN in the top right corner is May 22nd (the date for which the letter was produced and sent I believe). The recieving department sent the notice to Human Reources (Also the Plan Administrator) in early June at which time the HR team deemed it was a legitimate notice. The earliest enrollment date would then be the first of the following month from my understanding, making the effective date 7/1? The Medical Carrier agreed that this effective date was properly determined, however the Dental & Vision carrier is saying that we have to make the benefits effective on 5/22 since that is the date on the NMSN. The Employer didn't even have the notice on 5/22 so this seems incorrect. Has anyone heard of a carrier doing this? Maybe it's an inexperienced employee at the carrier that we are dealing with or maybe I'm interpretting the NMSN instructions incorrectly."

"I have a Plan that expected to terminate and pay out benefits prior to June 30, 2023. However, my document vendor (Ft William) doesn't yet have its Cycle 3 document ready, and says it won't have the doc until July sometime. All the benefits have been calculated for a June distribution. This is a small, non-PBGC-covered Plan and we are not submitting to IRS. Would you distribute anyway, and then update the document in July? Or? If we wait to distribute until after the docs are completed, we will have to recalculate everything."

"A takeover record keeper is asking for the Secure 1.0 amendment. It is not due until 12/31/2025 correct? I tend to doubt myself when institutions ask for things like this and imply that there should be one. We've been providing the Secure and Secure 2.0 good faith amendments for terminating plans only."

"I hope BenefitsLink neighbors will help me learn something about a particular oddity regarding remedial-amendment cycles. For optional changes a recent Act of Congress permits, a typical way a recordkeeper or third-party administrator knows what a plan’s sponsor adopted often results practically from the sponsor’s responses to a service provider’s solicitation of instructions. These sometimes involve not only express instructions but also implied assent to the service provider’s proposed default instructions. Even when a sponsor does not make or keep its own records, the service provider’s records of what it was instructed become a history that can support the remedial amendment. It seems at least some big recordkeepers did not (in 2020-2022) ask, even in implied-assent form, whether a sponsor wanted to change the applicable age for a required beginning date from 70½ to 72, and again have not asked whether a sponsor wants to change it to 73. Many plans’ documents still say 70½. If a service provider did not ask whether a sponsor wants an optional change in the applicable age for a required beginning date, how does one know what the plan provides? (I recognize that what service a provider was or is obligated to provide need not, and often does not, refer to what the plan provides.) Even if we expect 99.99% of sponsors would adopt all permitted changes to the applicable age, should service providers “go through the motions” of seeking a sponsor’s instruction (and proposing a default instruction) on the required beginning date applicable age? Or are there reasons not to ask?"

"I just recently started with a company and noticed that the company was grossing up STD and LTD premiums (adding the premiums into payroll and then deducting the same amount post tax), but it appears that the claims have been paid as if there was no gross-up (taxes were withheld and benefit was reported as taxable income) and the benefits broker has stated that the plans have always been quoted as non gross-up plans and that the plan documents would need to be updated to reflect this as being a gross-up plan. So my questions are this: -- What language specifically within the plan document(s) / contracts would need to change? I've never tried to compare language on a gross-up vs non gross-up plan? Is there typically language contained in the vendor contract the specifies if the plan(s) should be gross-up? -- For previous years, how or what type of correction should be done? Not sure if it makes sense to issue W2Cs for everyone, especially when everyone has already filed their tax returns. Can we simply make adjustments to the claims that were paid and that were improperly taxed? Anyone else experience this? Any suggestions on how to move forward?"