"Company A is selling Division Z to Company B with the close date being mid-month. Company A will stop providing health coverage to Division Z employees mid-month at close. Company B will start providing health coverage to these employees at close (no time without coverage). However, since Division Z employees were not offered health coverage for each day of the month at Company A, there will be a reporting gap for 1094 and 1095 purposes. Likewise, for Company B. Has anyone dealt with this before? Is there a workaround here to eliminate the coverage gap, other than requesting company A keep benefits turned on through the end of the month?"

"We have a Safe Harbor 401(k) plan that has a basic match formula (100% on the first 3% and 50% on the next 2%). They would like to add the automatic contribution arrangement that would be a flat 4%. Can a Safe Harbor plan add ACA (not EACA or QACA) at 4%? Also, can they change the formula to 100% match on the first 4% instead of the current formula? ... it looks like it's permissible assuming it applies to the entire year. In this case, I believe we will need to do 2 amendments. One amendment would amend the Safe Harbor formula effective 1/1/2024. The second amendment would amend the plan to flat 4% ACA, effective now. I would think that we can't combine these amendments in one, since the effective date for the Safe Harbor formula change has to be 1/1/2024, but the ACA feature was not available for the entire year, so it can't have an effective date of 1/1/2024. Would you agree?"

"Owner-only plan didn't file 5500-EZ in 2021 or 2022. Is it recommended to file the two late 5500-EZs separate from the timely filed 2023 Form 5500-EZ? It seems to me that filing them all together would make more sense since there wouldn't be a situation where the timely form is processed before the late forms, resulting in correspondence."

"I'm in WA state and have been on COBRA through my previous employer (I quit and went to work somewhere else) for around 10 months. I have paid on time every month and have been using the coverage with no issues. This weekend I received notice from a provider that they got a denial of payment for June services from my insurance because 'coverage was terminated'. I paid my June (and July) premiums to my former employer on time just like all the other months, and they took the money as usual. I never asked for my coverage to be terminated, did everything per usual on my end. There is no possibility of any issues with my payments, they are always done electronically and the billing office at my former employer confirmed receipt of each payment.... I looked at my insurance online and I see the EOBs that began denying claims starting in June. What are my legal options if my former employer ... stopped sending in my payments?"

"Father owns 100% of business and son over age 21 is only employee. I realize due to attribution rules the son also owns 100% -- so is this a one man plan that I can file a 5500 EZ, or do I need to do an Sf?"