401(h) Basics

Cash Balance Plan vs Money Purchase Plan: Which Plan is Better for 401(h)?

"Which host is better for a 401(h)?" is really the question "what is the medical account for?"

By 401h.com EditorialUpdated Jul 9, 20266 min read

Introduction

A 401(h) account can't stand on its own. The statute permits retiree medical benefits only as a feature of a pension or annuity plan — which rules out profit-sharing plans and 401(k)s as hosts.

This leaves two realistic candidates for a small-business owner: a defined benefit plan (in practice, usually a cash balance plan) or a money purchase plan. Both are qualified pension plans. Both can lawfully carry a 401(h) account and they produce dramatically different results.

This article works the mechanics of each, puts real numbers on the gap, and then maps the fact patterns where each host wins.

Why these two plans, and why the choice matters

§401(h) requires the medical account to ride on a pension plan — a plan providing definitely determinable benefits with a fixed employer funding obligation. A cash balance plan qualifies because it's a defined benefit plan.

A money purchase plan qualifies because, despite having individual accounts, it has a mandatory fixed contribution formula. This makes it a "pension" plan rather than a profit-sharing plan.

So which is better? The honest answer is it depends — and not in the hand-waving sense.

The two designs sit on opposite ends of a specific trade: the cash balance plan maximizes 401(h) funding capacity at the cost of actuarial complexity and expense, while the money purchase plan minimizes cost and complexity at the price of a much smaller medical account. Which one wins turns on measurable facts about the owner: age, income, how much medical funding they actually want, and what other plans they already run.

The choice of host matters because the host determines all three of the limits that cap the owner's 401(h) contribution:

  • §415(c): For a solo owner (always a key employee), 401(h) contributions are individual medical benefit account contributions and count against the defined contribution dollar limit — $72,000 for 2026. What else is drawing from that bucket depends on the host.
  • The 25% subordination test: The medical account is capped at roughly one-third of the pension contribution (under the common combined-base reading). The size of the pension contribution depends entirely on the host.
  • §404 deductibility: The deduction regime differs by host — actuarially determined DB funding versus the defined contribution 25%-of-compensation limit.

The cash balance host

A cash balance plan is a defined benefit plan, and that fact does two favorable things simultaneously.

First, the pension contribution is large. Cash balance contributions are actuarially determined and age-weighted; an owner in their 50s can routinely justify pension funding of $150,000–$300,000+ per year. That makes the subordination base big: a $200,000 pension contribution supports a 401(h) ceiling of roughly $66,667.

Second, the pension contribution stays out of the §415(c) bucket. DB accruals are tested under §415(b), not §415(c). With no other DC plan in the picture, the entire $72,000 annual-addition limit is available to absorb the 401(h) contribution alone.

Put together, a solo cash balance + 401(h) design can typically fund the medical account at the full subordination ceiling — often $60,000–$70,000 per year — with §415(c) slack.

The cost side. A cash balance plan requires an enrolled actuary, an annual actuarial valuation, Schedule SB certification, and minimum-funding compliance. Administration typically runs several thousand dollars a year more than a DC plan.

The sponsor also carries the interest-crediting obligation, which introduces modest funding volatility. None of this is exotic — it's the standard freight of any DB plan — but it's real, recurring overhead.

The money purchase host

The money purchase plan's appeal is exactly what the cash balance plan lacks: no enrolled actuary, no Schedule SB, no actuarial valuation. Contributions are a fixed percentage of compensation stated in the document, administration is ordinary DC-plan administration, and annual cost is a fraction of a DB plan's. For an owner allergic to actuarial complexity, it's the lightweight path to a 401(h).

The problem is arithmetic, and it comes in two layers.

Layer one: the shared §415(c) bucket. Money purchase contributions are themselves annual additions. So unlike the cash balance design — where the pension money is tested under §415(b) and leaves the DC bucket empty — the MPP contribution and the 401(h) contribution compete for the same $72,000. Maximize the pair subject to both constraints (401(h) ≤ one-third of the pension contribution; combined ≤ $72,000) and the best you can do is:

  • Money purchase contribution: $54,000
  • 401(h) contribution: $18,000
  • Combined: $72,000, with the 401(h) at exactly 25% of the total

Eighteen thousand dollars. That's the structural ceiling on a solo MPP-hosted 401(h) in 2026 — roughly a quarter of what the cash balance host supports.

Layer two: the 25%-of-compensation deduction limit. Since EGTRRA, money purchase plans are treated the same as profit-sharing plans for deduction purposes, which caps the employer deduction for defined contribution plans at 25% of participating compensation. An owner needs about $216,000 of W-2 compensation just to support the $54,000 MPP contribution in the illustration above. At $100,000 of W-2, the deductible MPP contribution tops out at $25,000 — and the subordination test then caps the 401(h) at roughly $8,333. The low-W-2 strategy that pairs so well with a cash balance host actively fights the money purchase host.

One further candor point: the deduction treatment of the 401(h) contribution itself on a money purchase host — whether it sits inside or outside the 25%-of-compensation base — is genuinely murkier than on a DB host, where the medical funding folds into the §404(a)(1) actuarial determination. MPP + 401(h) is a much rarer design than DB + 401(h), the authority is thinner, and anyone implementing it should get a specific opinion rather than relying on the DB-host conventions.

Side by side

Solo owner, age 55, no other plans, 2026 limits:

Comparison of Cash Balance Plan and Money Purchase Plan for 401(h) Hosts
Feature Cash Balance Plan Host Money Purchase Plan Host
Pension Contribution Capacity $150k–$300k+ (actuarial, age-based) ≤ $54k in practice (shares §415(c) with the 401(h)); deduction ≤ 25% of comp
Where Pension Money is Tested §415(b) — leaves DC bucket empty §415(c) — consumes the DC bucket
Realistic Max 401(h) ~$66,667 (subordination-bound) ~$18,000 (jointly bound), less at modest W-2
Enrolled Actuary / Schedule SB Required Not required
Annual Admin Cost Higher (DB-level) Lower (DC-level)
Funding Flexibility Actuarial range each year Fixed obligation — rigid but predictable
Low-W-2 Owner Fit Excellent (comp prong off for 401(h); DB funding not comp-driven in the same way) Poor (25%-of-comp deduction cap strangles both pieces)
Design Maturity Standard, well-trodden Rare; thinner authority on the 401(h) interaction
A detailed comparison table outlining the differences between Cash Balance Plans and Money Purchase Plans when used as a host for a 401(h) plan. Key features compared include pension contribution capacity, how pension money is tested against IRS limits, realistic maximum 401(h) contributions, requirement for an enrolled actuary, annual administrative costs, funding flexibility, suitability for low-W-2 owners, and design maturity.
Side-by-side comparison of key features for Cash Balance Plans and Money Purchase Plans, particularly as they relate to hosting a 401(h) account.

This table illustrates that Cash Balance Plans generally offer higher contribution capacities and better integration with 401(h) plans for low-W-2 owners, while Money Purchase Plans are simpler but more restrictive. Understanding these distinctions is crucial for employers selecting the optimal retirement vehicle for their specific needs.

So which is better?

The cash balance host wins when:

  • The owner is older and wants maximum funding — the age-weighted pension contribution creates a large subordination base, and the empty §415(c) bucket lets the 401(h) use it. This is the fact pattern where the roughly 4x capacity gap ($66,667 vs. $18,000) is decisive.
  • The owner runs modest W-2 wages. DB funding isn't throttled by the 25%-of-comp deduction cap the way DC funding is, and the 401(h)'s compensation-prong carve-out under §415(l)(1) does the rest.
  • The owner already wants a defined benefit plan anyway for the retirement side — the actuary is already being paid, so the 401(h) adds capacity at near-zero marginal complexity.

The money purchase host wins when:

  • The owner wants modest, predictable medical funding — say $10,000–$18,000 a year — and would never fund a cash balance plan at a level that justifies the actuarial overhead. If the medical goal is $15,000 a year, paying DB-level fees to unlock a $66,667 ceiling you'll never use is waste.
  • Simplicity and cost dominate. No actuary, no Schedule SB, no valuation. For a small, steady contribution the all-in cost difference compounds meaningfully over a decade.
  • The owner is younger, where the cash balance plan's age-based advantage is smaller anyway — a 35-year-old's CB contribution capacity may not be dramatically larger than what an MPP can deliver, shrinking the gap the actuarial fees are supposed to buy.

When neither plan works

When the owner is already maxing a 401(k)/profit-sharing plan. Those contributions consume the §415(c) bucket that the 401(h) needs under either host — but the money purchase design suffers doubly, since its own pension contribution competes for the same space.

If a companion DC plan is non-negotiable, the cash balance host is the only structure with a realistic path, and even then the 401(h) is limited to whatever dollar-limit room the DC plan leaves behind.

The takeaway

"Which host is better for a 401(h)?" is really the question "what is the medical account for?" If the answer is maximum tax-advantaged retiree health funding — the $60,000+-per-year version of the strategy — the cash balance plan is the only host that gets there, and the actuarial overhead is simply the price of admission.

If the answer is a modest, cheap, predictable medical benefit bolted onto a simple pension structure, the money purchase plan delivers it at a fraction of the cost — as long as the owner's W-2 supports the deduction math and everyone involved is comfortable with the thinner authority behind the design. The mistake is choosing the host before deciding which of those two strategies you're actually running.

Availability, tax treatment, and plan design depend on the facts and circumstances of the employer, plan document, participant group, and applicable law. 401h.com provides general educational information only — not tax, legal, actuarial, investment, or ERISA advice. Consult qualified tax, legal, actuarial, and plan professionals.

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401h.com Editorial

401h.com

The 401h.com editorial team publishes plain-English explainers on 401(h) retiree medical benefit plans. Educational only — not tax, legal, actuarial, investment, or ERISA advice.

Next step

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Talk with a 401(h) specialist about your plan, participant group, and retiree medical objectives.

Availability, tax treatment, and plan design depend on the facts and circumstances of the employer, plan document, participant group, and applicable law. 401h.com provides general educational information only — not tax, legal, actuarial, investment, or ERISA advice. Consult qualified tax, legal, actuarial, and plan professionals.