"Anyone else have clients getting extension letters from the IRS saying their 12/31/2022 PYE are 6/30/2023 PYE and their 5500 is extended to April? We have seen a few."

"We have a client with a safe harbor and cross tested profit sharing plan. They opted to maximize contributions for the owners. 5500 was filed and participant statements delivered. Now they do not have the money to fund the plan. Can they amend the profit sharing contribution and 5500 by still giving all the NHCE's the same contribution, but reducing the owners profit sharing to zero?"

"Other than SEPs (Medicaid/Chip), do you allow any PECs for adding a newborn beyond 30 days? I haven't gotten this question in a while but we have a plan with two requests -- one parent was admitted to an inpatient mental health facility right after the birth and one reportedly couldn't access the enrollment system (yet to be verified)."

"A provider initiated the IDR process by notifying a TPA and not the plan or issuer of the dispute. The TPA never forwarded the notice. The plan only learned about the determination -- which was issued with only input from the provider -- a year later. Is it a valid determination?"

"Participant has a vested balance of $75,000 including an outstanding loan balance of $15,000. The highest outstanding loan balance in the last 12 months is $35,000. If the loan limit is 50% of the vested balance not to exceed $50,000 reduced by the highest outstanding loan balance, what is the maximum amount available for loan? Fifty percent of the vested balance is $37,500; $15,000 is outstanding leaving $22,500 available for a loan. But $50,000 less $35,000 is $15,000; $15,000 is less than $22,500, thus $15,000 is the maximum amount available for loan. Good so far? So the Participant takes a loan for $15,000 and now has total outstanding loans of $30,000. Does it not stand to reason that since loans were maxed out that the Participant now has $0 available to take another loan? Let's do the math again. Participant has a vested balance of $75,000 including outstanding loans of $30,000. The highest outstanding loan balance in the last 12 months remains at $35,000. Fifty percent of the vested balance is $37,500; $30,000 is outstanding leaving $7,500 available for a loan. The $50,000 limit less $35,000 is $15,000. Now $7,500 is less than $15,000, thus, what do you know, now we have $7,500 available for a new loan! So Participant is told that he is maxing out his loans on one day, only to find more available for a loan after taking the 'maximum' loan the day before.... Do I have it right? Missing anything?"

"We have a client (individual medical practice) that is bringing in a group of 6 employees (5 employees plus 1 doctor) from a hospital. Of course the doctor would like to immediately participate in the medical group plan. We've used the predecessor service plan feature when a practice has been acquired. But I believe I read to use that feature there needs to be some business continuity relating to the group coming over."

"So some advise eliminating a waiting period or making it very short for part-time deferral-only employees. In the past if the plan was top-heavy they had to get 3%. 90% of our plans are top-heavy. And I know SECURE 2.0 eliminates top-heavy for those otherwise excludable. So if a plan allows all participants entry into the plan say after 12-month wait and entry date, those with a Year of Service (1000 hours) will get a full employer contribution and those without will not -- they can defer only. This will satisfy the LTPT requirement. There is no testing on the deferral-only group, and no top-heavy required contribution. This seems pretty easy except it's more enrollment for a plan sponsor. I believe our clients generally will still want the 12-month waiting period. Does this sound reasonable? Also, if it is a DC/DB combo, are there any consequences?"

"Plan makes a corrective allocation under EPCRS for a missed deferral and missed match in the form of a QNEC to the plan, plus attributable earnings. The RK is partly responsible for the error and offers to cover the cost of earnings on the QNECs involved. Question -- Can the RK fund the earnings directly to the Plan or should the RK reimburse the Plan Sponsor/Employer for the earnings amount by other means outside the Plan? Clearly, a corrective allocation must come from employer non-elective contributions (including forfeiture account if the plan allows 'use to reduce' method) but unclear part is whether the earnings attributable to the corrective allocation should also be required to be funded from ONLY employer non-elective contributions (including forfeitures)."