"Can a small group (1-49) offer Stand-alone Telehealth-Only Plan / Benefits After the End of the COVID-19 Public Health Emergency May 11, 2023, to Full-Time, Part-Time, Seasonal, 1099 Employees? I understand that relief is allowed for large employers (ALE) to continue to provide (stand-alone) solely telehealth and other remote-care benefits to employees or dependents who are not eligible for coverage under any other group health plan offered by the employer to the end of the 2023 plan year, including those benefit opt-outs ... Since telehealth only and other remote-care benefits are not listed as excepted benefits  ... a stand-alone telehealth or remote service plan offer after the end of the COVID-19 Public Health Emergency would need to meet many rules applicable to group health plans under ERISA, COBRA, HIPAA and the [ACA] minimum essential coverage rule ... even if offered by an small employer (1-49 FTEs), although a small employer (1-49 FTEs) is not required to offer ACA MEC or MVP coverage? Like restrictions of offering a stand-alone Health FSA without ACA MEC coverage by a small or large employer, of which the stand-alone Health FSA would not meet group health market reforms and ACA requirements for 100% preventive care benefits. I am interested to know other's thoughts or research for small employers on this subject."

"Partner A in Plan Origin terminated and had assets that required some attorney's involvement for liquidation (do not know the details) and Plan Origin is located in State A. Now ex-Partner A moves to State B and starts a PS plan -- Plan Destination. While in Plan Origin, with the help of the attorney, ex-Partner A was able to liquidate the assets within Plan Origin (1M dollars) and the attorney's fee was 20k i.e. 2% of the assets. Once all settled with Plan Origin, 1M dollars were rolled over to Plan Destination. This ex-Partner A now wants to pay the attorney's fees from the assets which are now in Plan Destination. Can he do that and if yes, is there a cite for it? My comment would be, no, as all events took place within Plan Origin and once rolled over to Plan Destination, it is no longer a Plan Destination related expense. Curious what others have to say."

"We are a TPA taking over a 401(k) plan that has a handful of self-directed brokerage accounts at Fidelity. The existing Fidelity accounts are 'non-prototype retirement accounts'. Has anyone had any luck in [reaching] of knowledgeable representatives at Fidelity in the correct department that can answer questions about these types of accounts, and if so, what phone number (and extension) have you been successful with? I've tried a couple different numbers and have had mixed luck with general questions. My goal is to try and save the Plan Trustee some time on the phone by getting him connected with the correct department / representatives from the start.... What about an e-mail address for the Service Support Group (SSG)?"

"Frozen plan with two owners. Their PVAB is in the 800k range. Next year with the 417(e) rates going up dramatically, the PVAB will be in the 600k range. I understand only the AB cannot be reduced, however, the PVAB can. However, will clients be upset that their PVAB is decreasing?"

"We have a client that is in the process of winding down a MEWA / VEBA and are trying to brainstorm a bit about how best to efficiently handle the remaining VEBA assets once all plan liabilities are satisfied. It appears there may only be ~$250k left over for a VEBA that covered a number of different participating employers of varying sizes and who have now all gone in many different directions so it's not as if there is one or two employers that could easily orchestrate a premium holiday, etc. While the trust can still get in touch with most all of the former participants, it seems trying to do anything along the lines of prepaying a portion of their new health or other benefits costs or trying to make distributions back to the former participants where possible will consume a lot of time and money and be an inefficient use of limited assets. Just curious if others have seen other VEBAs with limited surplus assets at termination find an acceptable and efficient way to address."