Church Plans and EINs

Q. When you have a church that sponsors a “steeple church” plan, will it also be the sponsor of plan that covers non-QCCO pre-school employees?

This is difficult because you have one entity, with possibly several “ministries” such as a pre-school, school, etc. that are not really separate entities from a business structure standpoint.

A. That is exactly what we told the IRS when they took away the ability to have QCCOs and non-QCCOs under the 403(b)(9).