"A plan has a Partial Plan Termination in 2025. None of the terminated participants have a balance. Should the terminated participants be 100% vested (in case they are re-hired in the future) or not (since they don't have an account balance at time of termination)?"

[Sponsored]

Discover how Enterprise Iron drives tech transformation, platform modernization, operational efficiency, and compliance solutions, and so much more. Secure, scalable, and built for your industry. Explore our services, case studies, and expert insights. 

"As the title says I just came across a plan document that defines a Break in Service as any year the participant works <1,000 hours. I don't recall ever seeing the number of hours being more than the <501. I have tried looking up the code and regulations and I see nothing that allows it that high number of hours."

"A 401k plan is a designed based safe harbor for both ADP and ACP testing; however, the plan allows after-tax contributions. The plan includes the match with the after-tax contributions to satisfy the ACP test (passes ACP just fine). My question is, how should Schedule R question 21b be answered (or 5500 SF 14b)? The question references both deferrals and match, without after-tax, the design would satisfy ACP."

"We just had qualifying event paperwork, for an employee that will be shifting from a PPO Health plan to a HDHP. The effective date is for 12/1/2025. Our insurance plan years are 1/1-12/31 which means after 1/1/26 we have new rates. Wouldn't refunding the employee in the current tax year for pre-tax benefits from the previous tax year also have tax implications? I thought if this happens we need to give them a refund that would include any medi, and local (Ohio) adjustments calculated, and adjust their W-2 information to reflect the change in benefits for the 2025 tax year."

"Now I have a situation with the employee that switched from PPO to an HDHP as of 12/1/2025. We received the Qualifying event paperwork today 1/7/2026. We have also switched HSA vendors as of 1/1/2026.

• We give employees a seed contribution when they sign up for the HDHP. Would the seed money that they would have received for the month of December 2026 be able to be applied to 2026?
• If the employee would be eligible for the December funds, would we need to attempt to deposit that money through the previous vendor?
• How should any of this affect their taxes and W-2?

I have reached out to our HR department and they asked us if we knew what to do, so I would love some regulatory backup for any answers."