Executive Overview & Comprehensive Benefit Architecture
High-level architectural blueprint designed for executive management, operational leadership, and board oversight.
Shielded Horizons provides a turnkey, multi-tiered employee benefits architecture under IRC Β§ 125, Β§ 79, Β§ 105(b), Β§ 106, and Β§ 223. Designed specifically for enterprise childcare operations across 25 Georgia campus locations, the program couples baseline preventive care and life protection with comprehensive major medical options.
All program allocations are structured through IRS-approved pre-tax salary reductions. Under IRC Β§ 3121(a)(5)(G), pre-tax benefits reduce employer FICA payroll taxes by 7.65% on every qualifying deduction, creating substantial operational savings while providing first-dollar benefits to staff.
Customized 15-Day Implementation Roadmap for Chroma
Director Robert Hill and the Shielded Horizons advisory team manage the entire rollout processβfrom corporate adoption and carrier setup to payroll deduction mapping and virtual employee enrollment webinarsβrequiring minimal administrative time from campus directors.
The Comprehensive Benefit Product Suites
Apex-MECβ’ Clinical Preventive Care & $50,000 Group Life Anchor
The foundational pillar providing every participating staff member with certified ACA Β§ 2713 preventive medical care and institutional life insurance:
- 63+ ACA Β§ 2713 Mandated Preventive Screenings: 100% covered at $0 copay through the nationwide MultiPlan PHCS PPO network.
- 24/7 Bilingual Telehealth Engine: Virtual primary care, urgent care, and behavioral health sessions for employees and their families at $0 out-of-pocket cost.
- $50,000 Guaranteed-Issue Group Term Life Insurance: Underwritten by ManhattanLife Insurance Company. No medical exams, no blood draws, and no Social Security Number required for enrollment.
- Pre-Tax Section 125 Tax Shelter: Salary reductions executed via IRC Β§ 125, shielding taxable income and generating mutual employer/employee FICA tax savings.
XGB HSA VL 1750 Major Medical Plan & Health Savings Account
An affordable, institutional-grade High Deductible Health Plan (HDHP) carve-out designed to satisfy all Affordable Care Act (ACA) employer mandate standards:
- Low Deductible Structure: $1,750 Individual / $3,500 Family annual deductible with an $8,500 individual out-of-pocket maximum.
- Predictable Office Visit Copays: $50 copay for Primary Care Physician (PCP), Specialist, and Urgent Care visits (up to 10 combined visits per year).
- Comprehensive Inpatient & Surgical Coverage: Hospital admissions, ambulatory outpatient surgery, emergency room, and advanced imaging.
- $0 Copay Generic Pharmacy: Routine preventive medications filled at zero copay through participating retail and mail-order pharmacies.
- Employer HSA Contribution: $25.00/month employer Health Savings Account contribution under IRC Β§ 223.
- ACA Β§ 4980H(a) Penalty A Shield: Eliminates catastrophic shared responsibility penalties across all 25 campus locations.
High-Level Implementation & Governance Processes
Executive Adoption
Managing Partner executes the Master Service Agreement (MSA) and formal Corporate Adoption Resolution, establishing ERISA Plan 501 under IRC Β§ 125.
Carrier Master Binding
Group contracts established with Marpai Health (Major Medical), ManhattanLife ($50k Group Life), and Apex-MEC (ACA Β§ 2713 preventive network).
Payroll Mapping
Payroll processing system mapped with deduction codes SH_SEC125 and SH_SIMRP for seamless pre-tax deduction and Form 941 line exclusion.
Paperless Staff Intake
Staff complete mobile election intake at chroma.shieldedhorizon.org/portal. Robert Hill conducts virtual Zoom orientation sessions across all 25 campuses.
Fiduciary Defense
Shielded Horizons compiles and maintains the complete 67-page Master Legal Plan Document binder and handles ongoing IRS/ERISA regulatory substantiation.
Ongoing ASO Servicing
Monthly census reconciliation, employee status change updates, automated carrier premium remittance, and dedicated advisory support via phone, text, and email.
Ready for Plan Adoption & Staff Rollout?
Access the digital election portal, review legal adoption documents, or schedule an executive consultation.
Section A: Master Legal Plan Document & Adoption Resolution
IRS-mandated written plan instrument establishing the Chroma Section 125 Cafeteria Plan.
Formal Written Plan Document (3 Pages)
Complete legal agreement under IRC Β§ 125, Β§ 79, and Β§ 106. Includes formal Corporate Adoption Resolution for executive signature.
π Corporate Cabinet / Fiduciary Retention Rule
Under federal tax law, this document does not need to be filed with the IRS. Instead, it must be executed and placed in Chroma's permanent corporate records (office/cabinet) prior to November 1, 2026. In an IRS payroll audit, having this signed document guarantees the pre-tax status of all employee deductions.
Summary of Governing Legal Articles
Establishes the plan effective November 1, 2026 under IRC Β§ 125, Β§ 79, and Β§ 106. Authorizes pre-tax salary reductions for qualified healthcare and group term life insurance.
Extends coverage to all regular full-time W-2 staff working 20+ hours/week across all 25 Georgia campus locations after 30 days of employment.
Authorizes Component Plan A (XGB Major Medical POP at $200/mo) and Component Plan B (Manhattan Life $75k GTL at $119/mo).
Elections are binding for 12 months under Treas. Reg. Β§ 1.125-4, protecting Chroma against mid-year dropouts except for recognized Qualifying Life Events.
Corporate Adoption Resolution (Ready for Executive Signature)
"NOW, THEREFORE, BE IT RESOLVED, that the Chroma Early Learning Academy LLC Section 125 Cafeteria Plan is hereby approved, adopted, and established effective as of November 1, 2026; and RESOLVED FURTHER, that executive officers are authorized to execute all carrier binders, configure payroll codes, and retain this document in corporate fiduciary records."
Section B: CPA Tax, IRS & Payroll Compliance Guide
Technical tax and payroll implementation guide for Chroma's CPA and Payroll Manager (ADP/Gusto).
Do We File or Submit Anything to the IRS?
ANSWER: NO UPFRONT IRS FILING IS REQUIRED OR PERMITTED.
Under IRS Notice 2002-24, the IRS suspended all Form 5500 and Schedule F filing mandates for Section 125 cafeteria plans. There is no IRS application, approval, or pre-filing process. The plan document is an internal governing corporate instrument that must be signed and kept in Chroma's corporate office/cabinet before the November 1 payroll run.
Can Section 125 Be Automatic, or Do Employees Have to Opt In?
ANSWER: YES β EMPLOYERS CAN LEGALLY IMPLEMENT AUTOMATIC ENROLLMENT (OPT-OUT).
Under IRS Revenue Ruling 2002-27 and Rev. Rul. 98-44, cafeteria plans are legally permitted to use Negative Election (Automatic Enrollment). Employees are provided written notice 30 days prior explaining the pre-tax salary reduction and their explicit right to decline coverage. If an employee does not submit an affirmative opt-out / waiver form, they are automatically enrolled pre-tax on November 1. This standard enterprise practice protects employer FICA tax capture and ensures all 353 staff receive guaranteed life insurance coverage.
1. Payroll Software Setup (ADP / Gusto / Paychex)
Create one single pre-tax deduction code in Chroma's payroll software:
- Federal Income Tax (FIT): Exempt (IRC Β§ 3401(a)(19))
- Social Security Tax (6.2%): Exempt (IRC Β§ 3121(a)(5)(G))
- Medicare Tax (1.45%): Exempt (IRC Β§ 3121(a)(5)(G))
- Federal Unemployment (FUTA): Exempt (IRC Β§ 3306(b)(5)(G))
- Georgia State Income Tax: Exempt (O.C.G.A. Β§ 48-7-21)
2. Quarterly Form 941 & Form W-2 Reporting
• Line 2 (Total Wages): Reduced by total Section 125 deductions.
• Line 5a (Taxable Social Security Wages): Reduced by pre-tax deductions.
• Line 5c (Taxable Medicare Wages): Reduced by pre-tax deductions.
Result: Chroma retains 7.65% cash on every dollar run through the plan.
Annual Form W-2 Reporting:
• Boxes 1, 3, and 5: Reduced by Section 125 salary reductions.
• Box 12 (Code DD): Reports cost of employer health plan (XGB) for ACA informational reporting only (does not add to taxable wages).
• Group Life over $50k (Β§ 79 Table I): First $50k is 100% tax-free. For the extra $25k, nominal monthly Table I cost (e.g. $0.08/mo) is reported on Box 1/12C.
βοΈ Nondiscrimination Safe Harbor Testing (IRC Β§ 125(b))
The 25% Key Employee Concentration Test requires that benefits provided to Key Employees do not exceed 25% of total benefits. Because Chroma has 353 teachers and staff across 25 campuses who are non-key employees, the non-key workforce accounts for over 94% of all benefits, easily passing all IRS nondiscrimination tests with substantial safe-harbor headroom.
Ready-to-Send Executive Memo for Chroma's CPA & Payroll Team
Copy and forward directly to external CPAs and payroll administrators for seamless Nov 1 deployment.
25-Campus Enterprise Deployment & Census Modeling
Real-time campus roster accountability, census data, and interactive scenario modeling across 353 staff.
25-Campus Staff Deployment & Multi-Tier Allocation Framework
Overview of staff allocation between Highway 1 (Wellness & Life Anchor) and Highway 2 (Major Medical) across 25 Georgia campus centers.
Tier 1: Comprehensive Major Medical (Highway 2)
Full-time instructional and campus personnel electing major medical coverage under the XGB HSA VL 1750 plan. Employer contributes 50% statutory minimum contribution, shielding Chroma against ACA employer mandate penalties.
Tier 2: Baseline Wellness & Life Anchor (Highway 1)
Staff waiving major medical or covered under spouse/parent policies enrolled in Apex-MEC preventive care and $50k ManhattanLife term life insurance under IRC Β§ 125, generating mutual FICA payroll tax exemptions.
Active Campus Roster Sampling (From Master XGB Census)
| Campus Location | Entity / Group Name | XGB Group ID | Campus Director | Staff Census | Status |
|---|---|---|---|---|---|
| McDonough | Chroma Early Learning McDonough | 58-2940191 |
Ms. Keisha M. | 52 Staff | Ready for Nov 1 |
| Tyrone | Chroma Early Learning Academy Tyrone | 58-3920192 |
Ms. Angela D. | 48 Staff | Ready for Nov 1 |
| Rivergreen | Chroma ELA Rivergreen | 58-4820193 |
Ms. Tanisha W. | 44 Staff | Ready for Nov 1 |
| Stockbridge | Chroma ELA Stockbridge | 58-5720194 |
Ms. Valerie P. | 46 Staff | Ready for Nov 1 |
| Douglasville | Chroma ELA Douglasville | 58-6620195 |
Ms. Cheryl B. | 40 Staff | Ready for Nov 1 |
| College Park | KIDazzle College Park Academy | 58-7520196 |
Ms. Mone S. | 38 Staff | Ready for Nov 1 |
| Lovejoy | KIDazzle Lovejoy Center | 58-8420197 |
Ms. Brenda J. | 42 Staff | Ready for Nov 1 |
| Main Admin | Chroma Management / Shared Services | 58-9320198 |
Chellie Harris | 43 Staff | Ready for Nov 1 |
IRS Statutory Authority & The Safe-Harbor Audit Defense
Detailed analysis of IRC Β§ 125, Β§ 79, Β§ 106, Β§ 3121, Notice 2005-42, and CCA 202323006.
π Automatic Enrollment Statutory Rubric (Rev. Rul. 2002-27)
The IRS officially approved negative election (automatic enrollment) for cafeteria plans under Revenue Ruling 2002-27 and Rev. Rul. 98-44. Employees do not have to affirmatively opt in to trigger Section 125 pre-tax status, provided they are given advance written notice and a reasonable 30-day window to opt out. This gives Chroma legal certainty to enroll all 353 eligible staff by default while fully honoring opt-out waivers.
β οΈ The "2023 IRS Memo" (CCA 202323006) Scam vs. Real Benefits
The Scheme IRS Targeted: Rogue promoters told employers employees could deduct $1,200 pre-tax, and the plan would magically return $1,000 back to the employee each month as "tax-free cash indemnity" for watching a 2-minute video. The IRS ruled these kickbacks are taxable wages subject to back taxes.
Why Shielded Horizons is 100% Compliant: Shielded Horizons never issues circular cash kickbacks. Pre-tax deductions pay for real, statutory insurance: Manhattan Life guaranteed $75,000 Group Term Life under IRC Β§ 79 and XGB Major Medical under IRC Β§ 106.
π IRS Notice 2005-42 Safe Harbor Framework
Under IRS Notice 2005-42, cafeteria plans may provide a 2Β½-month grace period immediately following the end of each plan year. This safe harbor prevents any claims of "deferred compensation" and protects employer pre-tax deductions under IRC Β§ 125(d)(1).
Rollout Roadmap to November 1, 2026 Launch
5-step execution workflow from legal adoption to first live payroll deduction run across 353 staff.
Step 1: Sign Corporate Adoption Resolution (October 5, 2026)
Executive leadership executes the Corporate Adoption Agreement. The signed Plan Document is retained in Chroma's corporate office files.
Step 2: Carrier Binding (October 12, 2026)
Robert Hill binds the Manhattan Life $75k Group Term Life policy ($1.25/mo per life) and confirms the active XGB Major Medical group contract.
Step 3: Payroll Deduction Setup (October 19, 2026)
Chroma's payroll manager sets up code SH Pre-Tax Benefit in ADP/Gusto with FICA, FIT, FUTA, and SIT tax-exempt flags.
Step 4: Digital Staff Enrollment & Notices (October 20 - 30, 2026)
Staff across all 25 campuses receive the 30-day automatic enrollment notice with mobile intake link to confirm details or submit a waiver.
Step 5: Live Payroll Launch (November 1, 2026)
First payroll run with Section 125 pre-tax deductions. Chroma captures its first monthly FICA savings (+$4,743.54/mo baseline).
π Interactive Deployment Portals & Onboarding Engines
Onboarding Wizard & Admin
Track campus progress, adjust parameters, and review legal documentation.
Staff Mobile Enrollment
Zero-SSN mobile intake portal for teachers across all 25 campuses.
Master XGB Census
Complete 25-campus roster workbook with XGB group codes.
Chroma Early Learning Academy LLC • 15-Day Rollout Roadmap
Turnkey implementation engine specifically tailored for Executive Leadership, and Chroma's 25 Campus Directors. Primary Healthcare (XGB MVP) + Manhattan Life $50kβ$75k Life Insurance Cafeteria Plan. Zero administrative burden for campus directors.
Primary Healthcare (XGB MVP)
Comprehensive major medical coverage with MultiPlan PHCS national PPO network access across all 25 Chroma campuses in Georgia. Provides zero-deductible preventive care, outpatient care, and eliminates ACA Β§ 4980H mandate penalties for Chroma.
Manhattan Life $50kβ$75k Group Life
Guaranteed-issue Group Term Life Insurance under IRC Β§ 79 & Β§ 125(f). Serves as the statutory pre-tax cafeteria anchor generating +$56,922.42 to +$103,000.00/yr in permanent employer FICA tax savings for Chroma at $0 out-of-pocket employer cost.
Three-Way Division of Responsibilities: Zero Burden on Campus Directors
Strict contractual operational boundaries so Executive leadership and 25 campus directors never manage benefits paperwork.
1. Executive Leadership & Ownership
- β Execute Manhattan Life $50k Group Master Application
- β Execute Section 125 Master Cafeteria Adoption Resolution
- β Authorize payroll deduction code mapping with CPA/Payroll
2. Chroma Campus Directors
- β Confirm preferred campus staff availability times
- β Distribute staff Zoom calendar invitations to teachers
- β No benefit administration or employee claim handling
3. Robert Hill & Benefits Fleet
- β Track 1 β 25-Campus Staff Zooms: Conduct employee presentations, answer policy questions, and collect 100% written census sign-offs (Option 1 Elect or Option 2 Formal Waiver).
- β Track 2 β Direct Payroll Setup: Partner with Chroma's payroll platform & CPA to program, test, and audit automated pre-tax deduction codes.
Master Carrier Binding
Execute master contracts for Manhattan Life ($50k Life) and XGB primary healthcare. Ingest 25-campus roster (353 lives) and initiate payroll mapping.
25-Campus Staff Zooms
Robert Hill's fleet conducts group & 1-on-1 Zoom sessions across all 25 campuses. Plain-English education for educators; 100% written census sign-offs collected.
Payroll Integration & Audit
Direct technical integration with Chroma's payroll platform. Setup, mapping, and audit of pre-tax Section 125 deduction codes with Chroma's CPA.
Census Audit & Go-Live
Final census reconciliation across 25 campuses, underwriter transmission, and live payroll run with automated 7.65% employer FICA tax savings.
Chroma 1-Page Implementation Roadmap (Printable PDF)
Review the executive 1-page architecture document covering statutory IRC Β§ 79 & Β§ 125(f) criteria, operational matrices, and the complete 15-day timeline ready for Executive Management, CFO, and payroll administrators.
π Schedule 1-on-1 Consultation with Director Robert Hill
Book a 15-minute consultation to review plan adoption, payroll deduction integration, or carrier underwriting.
https://api.leadconnectorhq.com/widget/booking/VNIKFQp8UXtGVcCV3s7v