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Safe Harbor Hardship Distributions -- Maximum Lookback for Determining Eligible Expenses?
BenefitsLink Message BoardsLink to more items from this source
Apr. 22, 2021

"A plan is using the safe harbor rules for hardship distributions. A participant incurred a medical expense in 2019 and has been paying the bill off over time. There is currently an amount still owed on the original expense. [1] Assuming the document is silent on this specifically, can the participant request a hardship for the amount of the medical expense that is still outstanding even though the original expense occurred two years ago? [2] If so, assuming the plan document allows for additional hardship restrictions, is it acceptable to say (for example) that hardships will only be allowed for an expense that occurred no more than 6 months from the date of the request?"

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