SIMPLE Plan enrollment period for Full Eligibility option

Enrollment period for SIMPLE plans is Nov 2 – Dec 31, 60 days long and employees must receive prior notice about an upcoming election opportunity.

Does this pertain to only the plans that have the “Limited Eligibility” option selected? We have a plan that selected “Full Eligibility”. So just wondering if selecting “Full” would give the employee’s the opportunity to enroll into the plan anytime of the year?

Also, for “Limited” or “Full” eligibilities, can you clarify below what it means “unless they first become eligible after the enrollment period of 11/2 – 12/31?

**Employee cannot enter the plan other than at the annual enrollment period (11/2 – 12/31) unless they first become eligible after the annual enrollment.



Plans offering full eligibility allow new employees immediate eligibility so are more likely to have mid year enrollments, but plans with limited eligibility may still have some employees qualifying mid year depending on the combination of the two limits. When first becoming eligible, they have 60 days to enroll. Employees who are eligible but do not enroll will have to wait for the annual enrollment period. 

Just so I’m understanding…Example of a plan that has the basic requirements where employee is expected to receive at least $5,000 in compensation in the current year and also received $5,000 during any previous  year.Employee hired April 2020Compensation $10,000 for 2020Compensation $30,000 for 2021 (would have Compensation of $5,000 by Mar 2021)Would this employee have 60 days from the time he reaches the Compensation of $5,000 or need to wait until the enrollment period between Nov 2 – Dec 31 for Jan 1, 2021Example of plan that has “full eligibility” requiremetnsEmployee hired May 1, 2021Employee is eligible to enroll and has 60 days from May 1st or wait until Nov 2 – Dec 31

“Reasonably expected to receive 5000” is a subjective determination of the employer. In this case the employee could have been expected to receive 5000 in 2021 if they were still on the payroll during the annual enrollment period last Nov, Dec. The employer need now wait until the current year 5000 has actually been earned. Notice 98-4 also states that in the year the employee first becomes eligible, they must be allowed to make contributions effective 1/1 of that year regardless of the 60 day period. (per Notice 98-4, E 1.)

Add new comment

Log in or register to post comments