Q. A steeple church has a pre-school that is a participating non-qualified church-controlled organization (QCCO). The pre-school is under the EIN of the church.
When we restate our plan, we will be utilizing two different documents for them — the steeple church will be on one document, and the pre-school (as a non-QCCO) on another document. Obviously, the church will sponsor the “steeple church” plan. Will the steeple church also be the sponsor of plan that covers non-QCCO pre-school employees? Do we exclude employees who perform services for the non-QCCO from the church’s plan, and vice versa?
A.It could be done that way, or the school could adopt the separate plan.
When we restate our plan, we will be utilizing two different documents for them — the steeple church will be on one document, and the pre-school (as a non-QCCO) on another document. Obviously, the church will sponsor the “steeple church” plan. Will the steeple church also be the sponsor of plan that covers non-QCCO pre-school employees? Do we exclude employees who perform services for the non-QCCO from the church’s plan, and vice versa?
A.It could be done that way, or the school could adopt the separate plan.
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