"I have a DCFSA participant requesting to reduce her annual election mid-year due to the fact that her child will be starting kindergarten this Fall. Since the participant knew that the child would be starting kindergarten this year, it doesn't seem like this would be an acceptable qualfiying event. Thoughts?"

"Hypothetical Scenario A cash balance plan has a provision that states participant and spouse must consent to distributions over $1,000. The plan terminates and the plan thought the spousal consent was the standard IRC $5,000. Lump sum benefits between $1,000 and $5,000 were paid out with participant consent, but not spousal consent. The plan realizes the mistake and wants to do a post-Date of Plan Termination amendment to change the provision to state a participant and spouse must consent to a distribution over $5,000. Reviewing CFR 4041.8 Post-termination amendments, it seems like an amendment is allowed that does not [1] decrease the value of the participant or beneficiary benefit and [2] does not eliminate or restrict any form of benefit. To me, this post-DOPT amendment only limits a spouse's right to consent to the distribution. It does not decrease the value or eliminate or restrict any form of benefit. Would this type of amendment be prohibited?"

"Employee (in Florida) did not enroll children in employer plan because they were enrolled in Medicaid. Employee lost Medicaid coverage for the children due to income level but the children are instead eligible for the state's 'Medically Needy' program, which basically means that Medicaid will kick in once a (rather large) deductible is satisfied. Does this constitute a 'loss of Medicaid coverage' giving rise to a HIPAA special enrollment event? Thanks!"

"I posted a similar question not too long ago but I'm really reaching out to anyone that uses the same document provider and type of documents we use. Which are the FIS/Relius pre-approved IDP Volume Submitters Plan documents. We are trying to determine if there's an easy way to amend our plans that don't currently allow Roth Deferrals to allow them to comply with the Secure Act Roth catch-up provision for 2024. We can't seem to get a clear answer from FIS..it seems there is no way to amend a FIS/Relius IDP VS to add Roth 401k deferrals, without losing reliance. We are trying to avoid restating since we recently restated all plans for Cycle [3] We were hoping that they would provide a regulatory amendment to add the Roth Deferrals but that doesn't seem to be the case. If you use these types of documents, are you restating the plan documents now to add Roth deferrals?"