"[T]he employer is only responsible for determining the following with respect to each employee: [1] whether the employee is covered under an HDHP or a non-HDHP (e.g., a general-purpose health FSA or HRA) sponsored by that employer; and [2] the employee's age, for determining whether the employee is eligible for age 55 catch-up contributions (the employer may rely on employees' representations as to their dates of birth)."  MORE >>