🛡️ SHIELDED HORIZONS LLC • MASTER CLIENT COMPLIANCE BINDER
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Master Section 125 & SIMRP Compliance Manual

Formal statutory policies, administrative standard operating procedures (SOPs), legal underwriting defenses, and client adoption agreements established under ERISA Section 3(16)(A), IRC § 105(b), § 106, § 125, § 79, and § 213(d). Operating in-house without outside commercial TPA leakage.

🛡️ Fiduciary Verification & Audit Q&A

Highlights of Operational Proof: How We Prove Full Statutory Compliance

Direct, verifiable answers to the core regulatory questions asked by underwriters, employer HR directors, and DOL/IRS auditors. Click any question to navigate directly to the governing policy, statutory citation, or proof artifact.

1
How We Prove We Are In-House Without a TPA (SOP 1)
Under ERISA § 3(16)(A), the employer is the statutory Plan Administrator by default. The Master Administrative Services Agreement (ASA) formally delegates ministerial execution to Shielded Horizons LLC pursuant to 29 CFR § 2509.75-8 (D-2). This retains full fiduciary control and administrative fee capture within Shielded Horizons without revenue leakage to external commercial TPAs.
2
How We Prove Insulation from IRS Audits / CCA 202323006 (SOP 5)
The policy manual states as an inviolable rule that Shielded Horizons pays $0.00 in cash indemnity, bonuses, or cash rebates to employees. 100% of the employee pre-tax allocation is paired with active physician clinical care through Apex-MEC Clinical Preventive Care (Treas. Reg. § 1.213-1(e)(1)(ii) & ACA § 2713) and statutory group term life insurance underwritten by ManhattanLife (IRC § 79 & § 125(f)). There is no circular cash loop.
3
How We Prove No Hourly Worker Is Underpaid (SOP 4)
The manual codifies the exact pre-payroll mathematical formula:
Available Headroom = (Hourly Rate × Hours Worked) - ($7.25 × Hours Worked)
If an hourly employee works reduced hours, the automated census engine automatically suspends or prorates the deduction for that payroll period, guaranteeing the employee never falls below the federal $7.25/hr minimum wage.
4
How We Prove Tax Exemption to ADP / Paychex / QuickBooks (SOP 3)
The manual provides the exact statutory crosswalk table showing why deductions are exempt from Federal Income Tax (IRC § 105(b)/§ 125), Social Security and Medicare FICA (IRC § 3121(a)(2)(B)), and Federal Unemployment FUTA (IRC § 3306(b)(2)(B)). Mapped as two columns: pre-tax salary reduction paired with non-elective flex credits for $0.00 net pay impact.
5
How We Prove Real Economic Medical Value ($168–$265/mo Retail Equivalent)
Benchmarked against independent commercial catalogs (TWP Catalogue 2022 / Teladoc fair-market rates): 24/7 unlimited physician urgent care ($85–$120/mo), tele-mental health ($65–$110/mo), and $50k group life ($18–$35/mo) delivers verified market-rate medical care substantiating real economic medical value under Treas. Reg. § 1.125-1.
6
How We Prove the Plan Passes Annual Non-Discrimination Testing (NDT) (SOP 7)
Under IRC § 125(b)(2), no more than 25% of statutory benefits may go to Key Employees (> $220k compensation or > 5% owners). Across our corporate hourly groups (such as Chroma Early Learning with 353 staff), Key Employees represent less than 2% of enrollment. Eligibility is uniform (30 days of service) and benefits are equal ($0 copays for all staff), guaranteeing an annual audit pass.
7
How We Prove Insulation from ACA Employer Mandate Penalties (Penalty A & B)
Under IRC § 4980H, employers with 50+ FTEs face $2,970/worker (Penalty A) and $4,460/worker (Penalty B). Shielded Horizons eliminates Penalty A by offering 100% of staff an ACA § 2713 / § 5000A(f) compliant preventive care plan (Apex-MEC Clinical Preventive Care) with $0 copays, backed by electronic waiver tracking. We eliminate Penalty B by pairing the plan with a qualifying Minimum Value Plan (MVP / Major Medical), using Section 125 FICA savings ($600–$900/worker/yr) to subsidize premiums below the IRS 8.39% W-2 Affordability Safe Harbor. (Small employers under 50 FTEs are 100% exempt by statute).
📍 Where It Appears in the System:
🌐 Public HTTPS Portal: wimper.shieldedhorizon.org/shielded-policy
⭐ Featured Card #0 in Legal Library: wimper.shieldedhorizon.org/compliance_docs/
📋 Top Navigation Button in Client Binder: wimper.shieldedhorizon.org/client-binder

8-Step Statutory Compliance Protocol & Audit Checklist Satisfying All 8 Library Filings

This standardized audit protocol outlines the eight required statutory milestones enforced by Shielded Horizons LLC for Chroma Early Learning Academy LLC. Every requirement corresponds directly with our library of legal underwriting opinions and federal agency joint rulings.

Milestone Governing Regulation Supporting Library Document Execution Status on File
1. Written Plan Document Treas. Reg. § 1.125-1(c) WIMPER Key to Compliance 2024 ✓ Adopted (Plan #501)
2. Anti-Abuse Indemnity Defense IRS CCA 202323006 & § 213(d) Legal Underwriting Opinion PLLS ✓ Safe Harbor Insulated ($0 Cash)
3. Participatory Wellness Safe Harbor 42 U.S.C. § 300gg-4(j)(3)(C) Federal Register (78 FR 33158) ✓ 100% Health Contingent Exempt
4. Payroll FICA/FUTA Tax Exclusion IRC § 3121(a)(2) & § 3306(b)(2) PCM Program SIMRP Tax Crosswalk ✓ Two-Column Mapping Validated
5. Fair-Market Retail Valuation Treas. Reg. § 1.125-1 TWP Retail Catalogue 2022 ✓ $168–$265/mo Retail Documented
6. In-House Fiduciary ASO Designation ERISA § 3(16)(A) & 29 CFR 2509.75-8 WIMPER Statutory Compliance Guide ✓ Shielded Horizons Designated
7. HIPAA Data Protection & BAA 45 CFR § 164.502 / § 164.504 Health Compass White Pages ✓ Executed 24-hr Breach SLA
8. Non-Discrimination & FLSA Audit IRC § 125(b)(2) & 29 U.S.C. § 206 SIMRP Compliance Checklist ✓ <2% Key Concentration (Pass)
Audit Safe Harbor Confirmation
The program eliminates outside commercial TPA leakage, preserving 100% of the $100.00–$120.00 PEPM administrative fee for Shielded Horizons LLC while immunizing Chroma Early Learning Academy LLC against IRS and DOL regulatory challenge.

Section 125 Cafeteria Plan Policy & Procedures Manual Plan Year: 2026

Article I: Establishment and Purpose

Chroma Early Learning Academy LLC ("Plan Sponsor") hereby enacts and maintains the Flexible Benefits Cafeteria Plan (Plan 501). The primary purpose is to enable eligible W-2 employees to elect pre-tax statutory benefits in lieu of taxable cash compensation, in full accordance with Internal Revenue Code Section 125.

Article II: Eligibility and Participation

1. Service Requirement: All active employees completing thirty (30) days of continuous employment are eligible to enroll.
2. Eligible Group: Includes all full-time and part-time educators and support staff across the client's campuses (currently 353 active employees).
3. Irrevocability Rule: Pursuant to Treasury Regulation § 1.125-4, elections cannot be revoked or modified during the 12-month Plan Year except upon a certified Qualifying Life Event (QLE) submitted within 30 days.

Article III: Benefit Schedule and Mechanics

Article IV: Employer Flex Credits & Net Pay Protection

To ensure employees experience zero out-of-pocket payroll reduction, Chroma Early Learning Academy LLC allocates a non-elective monthly Employer Flex Credit under IRC § 125(f). The credit exactly balances against the pre-tax salary reduction, providing 24/7 virtual urgent care and life insurance at $0.00 net change in employee take-home pay.

Statutory Compliance Guide & IRS CCA Anti-Abuse Defense Legal Safe Harbor Analysis

The IRS Audit Vulnerability in Generic Wellness Plans
IRS Chief Counsel Advice memos (CCA 201438022, 201703013, 202022010, and 202323006) strictly prohibit arrangements that deduct pre-tax dollars from employee paychecks and return tax-free cash reimbursements, cash indemnity bonuses, or wellness payments without an actual, substantiated medical expense under IRC § 213(d).

How Shielded Horizons Completely Insulates Chroma Early Learning Academy LLC

  1. Complete Elimination of Cash Indemnity: The Plan pays $0.00 in cash distributions, cash rebates, or payroll bonuses to participants.
  2. Direct Clinical Preventive Medical Care: Every pre-tax allocation delivers legitimate, certified clinical preventive care, physical examinations, and diagnostic lab screenings through Apex-MEC (MultiPlan PHCS Network), satisfying IRC § 213(d)(1)(A), ACA § 2713, and Treasury Regulation § 1.213-1(e)(1)(ii).
  3. Statutory Life Insurance Anchor: The $50,000 Group Term Life benefit underwritten by ManhattanLife Insurance Company is explicitly enumerated in IRC Section 79 and IRC Section 125(f).
  4. Participatory Wellness Exemption: Operates strictly under 42 U.S.C. § 300gg-4(j)(3)(C) and Joint Final Rules (78 FR 33158) as a voluntary participatory program with zero biometric or outcome-based testing.

Legal Underwriting Counsel Conclusion

As affirmed in the independent legal underwriting counsel opinion by Attorney George K. Brew (P.L. Legal Services), the pairing of legitimate virtual physician access with statutory group life insurance under an in-house Section 125 cafeteria plan satisfies all federal statutory tests and is immune from IRS circular reimbursement enforcement.

Statutory Tax Crosswalk & Payroll Mapping Schedule IRS & DOL Tax Exclusions

The following statutory citations govern payroll processing and tax reporting for Chroma Early Learning Academy LLC (EIN: 58-2940191):

Tax Category Statutory Code Authority Payroll Treatment W-2 Reporting Impact
Federal Income Tax Withholding (FIT) IRC § 105(b), § 106(a), § 125(a) Pre-tax deduction from gross wages Excluded from Box 1 (Wages)
Social Security (FICA - 6.2%) IRC § 3121(a)(2)(B) Exempt from Social Security tax Excluded from Box 3 (SS Wages)
Medicare (FICA - 1.45%) IRC § 3121(a)(2)(B) Exempt from Medicare tax Excluded from Box 5 (Medicare Wages)
Federal Unemployment (FUTA - 0.6%) IRC § 3306(b)(2)(B) Exempt from employer FUTA liability Excluded from taxable FUTA base
State Unemployment (SUTA) Conformity with IRC § 3306 Exempt from employer SUTA liability Excluded from state wage base
State Income Tax (SIT) State Conformity with IRC § 125 Pre-tax deduction from state wages Excluded from Box 16 (State Wages)

Annual Employer FICA Recapture Calculation

By reducing taxable payroll across 353 enrolled W-2 staff, the employer recaptures 7.65% in payroll taxes ($600.00+ annually per participating employee), generating substantial financial savings that fund the in-house administrative fee and enhance employee benefits.

Fair-Market Retail Valuation Schedule (TWP Benchmark) Substantiation Under Treas. Reg. § 1.125-1

Pursuant to IRS substantiation guidelines and the retail pricing catalog on file, the fair-market consumer retail value of the clinical and life insurance benefits provided to employees of Chroma Early Learning Academy LLC dramatically exceeds wholesale provider costs:

Benefit Description Clinical & Underwriting Carrier Independent Consumer Retail Worth Fair Market Source
Apex-MEC™ Clinical Preventive Care
63+ ACA § 2713 screenings, annual physicals, preventive labs
Apex-MEC / MultiPlan PHCS Network $95.00 – $140.00 / month Commercial ACA Preventive Benchmark
Elective 24/7 Urgent Care & Virtual Mental Health
Board-certified virtual physicians and licensed counselors
Clinical Telehealth & Mental Health Network $55.00 – $90.00 / month Commercial Telehealth / EAP Benchmarks
$50,000 Guaranteed Issue Group Life
Underwritten by ManhattanLife Insurance Co.
ManhattanLife Insurance Company (IRC § 79) $18.00 – $35.00 / month Commercial Retail Term Rates (Age 35-50)
TOTAL BENEFIT PACKAGE DELIVERED Fully Insured Master Carrier Policies $168.00 – $265.00 / month Statutory Safe Harbor Satisfied
Legal Substantiation Ratio
The documented retail consumer value delivered to each employee ($168–$265/mo) substantially exceeds statutory minimums, proving conclusively that the pre-tax salary reduction corresponds with bona fide economic medical value and active clinical care under federal law.

In-House Fiduciary ASO Contract & HIPAA BAA ERISA § 3(16)(A) Designation

Master Administrative Services Agreement (ASA)

Effective Date: January 1, 2026
Plan Sponsor (Client): Chroma Early Learning Academy LLC (EIN: 58-2940191)
Contract Administrator: Shielded Horizons LLC, 3554 Old Milton Pkwy, Alpharetta, GA 30005

1. Ministerial Delegation: Pursuant to ERISA Section 3(16)(A) and 29 CFR § 2509.75-8 (D-2), Employer designates Shielded Horizons LLC as Contract Administrator to perform ministerial eligibility verification, census intake, two-column payroll deduction mapping, direct carrier premium pass-through remittances, and non-discrimination testing.
2. Operating In-House: Employer designates Shielded Horizons LLC to execute administration in-house without engaging an outside commercial TPA.
3. Compensation: Plan administration and ministerial execution fees are authorized pursuant to the approved Fee Schedule, fully funded out of corporate payroll tax recapture and plan operations with zero net out-of-pocket cost to the employer or employees.

HIPAA Business Associate Agreement (45 CFR § 164.502/504)

Shielded Horizons LLC warrants full compliance with the HIPAA Security and Privacy Rules, implementing administrative, physical, and technical safeguards for employee protected health information (PHI), and guaranteeing 24-hour breach notification.

For Plan Sponsor: Chroma Early Learning Academy LLC
Chellie Harris, Director of HR
Authorized Officer
For Contract Administrator: Shielded Horizons LLC
Robert Hill
Managing Director (GA Lic #19559059 • NPN #839439)

Corporate Board / LLC Plan Sponsor Adoption Resolution Formal Legal Action

Entity Name: Chroma Early Learning Academy LLC
Federal Tax EIN: 58-2940191
Date of Action: January 1, 2026

UNANIMOUS WRITTEN CONSENT OF MANAGING OFFICERS:

"WHEREAS, it is in the best interests of Chroma Early Learning Academy LLC and its employees to establish a Section 125 Flexible Benefits Plan and Self-Insured Medical Reimbursement Plan (Plan 501);

NOW, THEREFORE, BE IT RESOLVED, that the Company hereby approves and adopts Plan 501 effective for the 2026 Plan Year;

FURTHER RESOLVED, that the officers of the Company be authorized to execute the formal Written Plan Document and designate Shielded Horizons LLC as ministerial Contract Administrator / In-House ASO Provider under ERISA Section 3(16)(A);

FURTHER RESOLVED, that the Company's payroll department and processors be authorized to execute pre-tax salary reductions pursuant to signed employee election agreements."

Authorized Managing Member / Officer Signature:
Chellie Harris, Director of HR
Chroma Early Learning Academy LLC

Employee Intake: Salary Reduction & Wellness Attestation Digital Intake Template

Part A: Irrevocable Pre-Tax Salary Reduction Election (Treas. Reg. § 1.125-4)

"I hereby elect to participate in the Chroma Early Learning Academy LLC Section 125 Plan for the 2026 Plan Year. I authorize pre-tax salary reductions to fund my statutory benefits, balanced by my non-elective employer flex credit. I understand this election cannot be changed during the Plan Year except upon a recognized Qualifying Life Event."

Part B: Primary Beneficiary Designation ($50,000 ManhattanLife Group Life)

Primary Beneficiary Name: [BENEFICIARY_FULL_NAME]
Relationship to Employee: [RELATIONSHIP]
Phone & Email: [BENEFICIARY_CONTACT]
Benefit Allocation: 100%

Part C: Annual Participatory Wellness Agreement (42 U.S.C. § 300gg-4(j)(3)(C))

"I agree to participate in the Annual Participatory Wellness Program administered by Shielded Horizons LLC. I understand I have full access to Apex-MEC Clinical Preventive Care and screenings at $0 copay. Participation is entirely voluntary and is available to all eligible employees regardless of health status."

Enrolled Employee Electronic Signature & Timestamp:
[EMPLOYEE_PRINTED_NAME]
Campus / Location: Chroma Early Learning Academy LLC
Shielded Horizons LLC • 3554 Old Milton Pkwy, Alpharetta, GA 30005 • GA License: 19559059 | NPN: 839439
Fiduciary In-House Administration under ERISA § 3(16)(A) & Internal Revenue Code Safe Harbors