"I'm looking for service provider recommendations to determine Creditable Coverage re: Medicare Part D. We have a client who has a high deductible health plan combined with an HRA that needs to obtain an actuarial determination as soon as possible. It's a small client (roughly 45 employees) so any referrals to firms that are affordable (if at all possible) would be greatly appreciated."

"I'm a small business owner, and in no way a benefits expert. Our company has only 8 people in the plan. 5 of those 8 have ownership above 5% and thus are HCE as I understand it. One more has a salary in excess of 150k, thus also an HCE. We offer a 100% on the first 3% and 50% on the next 2% for our match. We also have a profit sharing component to the plan. My understanding is that because we have the safe harbor plan, we're exempt from testing (ADP, top-heavy, etc) for the primary 401k. However, our TPA is informing us that there is testing associated with the profit sharing component. Is this correct? We're looking to max out our portion as owners, and provide a different but equal amount to the two non-hce's and a 3rd amount to the one HCE that is a non-owner. My further understanding of the profit share is that we can only 'share' up to 25% of the total compensation of all eligible employees, but that the money is pooled. eg, 8 employees each making 100k, we would have no more than 200K that could be put into the profit share portion, and no single employee could crest the 69k combined threshold (unless with catchup contribution). I'm hopeful someone here can provide some additional insight for me. If we make a 'profit share contribution' to all employees, HCE and Non, are we subject to testing? If so, is there anywhere where I can plug in our numbers and understand my options? Additionally, do we need to provide the same to all non-owner or non-hce's?"

"Participant takes a loan from the 401(k) Plan to pay for the higher education expenses of their dependent or themselves or their spouse. Why does this not qualify as a 'Qualified Student Loan'? Answer: SECURE inddicates that the following definition applies to qualifying student loans: 221(d)(1) Qualified education loan. The term 'qualified education loan' means any indebtedness incurred by the taxpayer solely to pay qualified higher education expenses -- (A) which are incurred on behalf of the taxpayer, the taxpayer's spouse, or any dependent of the taxpayer as of the time the indebtedness was incurred, (B) which are paid or incurred within a reasonable period of time before or after the indebtedness is incurred, and (C) which are attributable to education furnished during a period during which the recipient was an eligible student. Such term includes indebtedness used to refinance indebtedness which qualifies as a qualified education loan. The term 'qualified education loan' shall not include any indebtedness owed to a person who is related (within the meaning of section 267(b) or 707(b)(1)) to the taxpayer or to any person by reason of a loan under any qualified employer plan (as defined in section 72(p)(4)) or under any contract referred to in section 72(p)(5)."

"Does anyone has experience with merging a non ERISA church 401k or 401a into a Non ERISA Church 403b plan? This is permitted under Code Section 414(z) as implemented by the PATH Act of 2015. I am interested in the mechanics of how to do this -- lets say the 401k is the existing plan, but the Church wants to have non ERISA 403b plan. Would the client need a Board Resolution, along with a new 403b plan into which the current 401k can be merged? I believe there is a requirement that all accounts that are merged be nonforfeitable -- i.e. fully vested. I realize there are no regulations on this issue to date. Any thoughts would be appreciated!"

"First, was sorry to hear of Mike Preston's passing. I had been using his PPA Present Values software for checking purposes for a number of years, and with his passing it is no longer supported for interest and mortality updates. Any other standalone software alternatives that are recommended?"