"We have a client that would like to provide “concierge medical benefits” to all of its employees that have elected any level of medical plan coverage, which is provided under a fully-insured high deductible plan. There are no actual medical benefits being provided via the concierge program. Instead, the client has contracted with two geographically convenient general practitioners that will give “high” or “immediate” scheduling priority to participants, as well as much quicker response to requests for refills, etc. Actual medical expenses associated with the services will be run through the group medical plan as usual (e.g., cost of the visit, medical tests, etc.). From the client’s description, it seems like the concierge service is merely a program to provide priority scheduling and refills. The projected cost for each employee is $2,000/year. I am not sure if there is a different cost if the employee has elected family coverage, but in any event, it will all be employer paid. Our practice is primarily focused on qualified and nonqualified plans, so this is out of the box for us. At first blush, this program does not seem to be a welfare benefit plan, and I am thinking that the cost would be includable in the employee’s income. Hoping someone has some experience with this type of program and can point us in the right direction."

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"3% SHNEC Safe Harbor Plan. Client wants to discontinue the SHNEC but a) the keys have already made substantial 401k, and b) they are top-heavy. Can we discontinue the SHNEC as of April 30th (after providing the 30 days notice of course) and coincidentally create a short plan year ending 4/30/2025, and remain on a 4/30 plan year end for the foreseeable future? I'll be darned if that doesn't work. I think it does... Otherwise he has to terminate the plan and everyone loses (because terminating is the only way to stop the top-heavy minimum). Of course all keys would be told to stop doing 401k (in fact I have made it my practice to exclude keys from the plan by design (I called it a top-heavy inoculation)."

"I'm exploring the feasibility of integrating PensionPro with a SharePoint spreadsheet to automate the tracking of workflows. I would appreciate a recommendation for a developer/programmer. Thank you."

"I just learned that the 1099-Rs for a 2024 RMD and plan closing rollover to an IRA were not filed. I created the forms but the 1096 needs to be signed. What are my options? Can I sign the form as a "paid preparer"? Could I apply for a PTIN and file the return?"

"Plan allows for immediate distributions, and participant K separates from service and takes her money out ASAP. Now we're doing the annual admin, and she is due $40 in safe harbor nonelective. If the sponsor puts it into her account, it will get eaten by distribution fees; K will never see any of it. But I don't think that the sponsor should benefit from this situation. Is there a best practice for doing something relatively meaningful with this $40? Thanks."