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Frequently Asked Questions by Employers (Employer FAQ)

Very Frequently Asked Questions by Employers

CCC is neither qualified nor licensed to provide financial or tax advice. To the extent answers to questions below deal with Federal or State income tax information, any information provided is not intended or written by CCC to be used, and cannot be used by any taxpayer, for the purpose of avoiding any penalties that may be imposed under the Internal Revenue Code. Information from CCC relating to Federal tax matters may not be used in promoting, marketing or recommending any entity, investment plan, or arrangement to any taxpayer.

  1. Exactly what is a 403(b) Plan?
  2. What Form W-2 Codes should be used for 403(b) elective deferrals, Roth 403(b) contributions, employer 403(b) contributions, 457(b) elective deferrals, Roth 457(b) contributions, and employer 457(b) contributions?
  3. Is it possible for us to offer a Retirement Incentive Program that avoids payroll taxes and allows participants to defer Federal and State income taxes?
  4. We are offering an Early Retirement Incentive (ERI) program in which eligible employees may elect a lump-sum payment, a monthly stipend for a specified number of years, or a combination of these two. Do employees who decide to participate have the option to defer any portion of these payments into their 403(b) or 457(b) accounts?
  5. How does an employer determine if an employee is technically "severed from employment" as it pertains to the 403(b) and/or 457(b) Plan?
  6. The Salary Reduction Agreement for our District is labeled as "Draft - Not for Current Use". Should I continue to use the form we have used in the past or is an approved format available soon.?
  7. In reviewing our section of the CCC website I notice that the following message is on all of our vendor pages: "This Vendor Page has not been approved by American Century Investments, but the information provided should be useful to you." Is there something we need to do in this regard?
  8. We are facing RIF situations. What sort of fact sheet might we include in packets for those affected?
  9. How do I handle returned remittance checks from Vendors?
  10. We have received a check from a mutual fund company that may be used to offset Plan expenses. What should I do with this check?
  11. Some of our Employees have received checks from Vendors that are payable to the Employer. These checks deal with a settlement stemming from an investigation into alleged market timing within the Scudder Family of Mutual Funds. What should I suggest that these Employees do with these checks?
  12. What happens if a substitute teacher or other part-time employee specifies a flat amount to be deferred and doesn't earn enough to make the specified deferral?
  13. Someone told me that our policies allowing employees to elect 403(b) TSA contributions in lieu of health insurance premiums is a problem that must be corrected. What's the problem with this?
  14. Do we need to notify vendors of our TPA relationship with CCC?
  15. What is the process to add a preferred provider to my employer's list of vendors?
  16. Are Life Insurance Policies no longer allowed in 403(b) accounts?
  17. Does CCC provide financial or investment advice?
  18. Where should our employees go for financial or investment advice?
  19. Does PERS affect 403(b) or 457(b) contributions of our employees?
  20. Does CCC participate in Employer Benefit Fairs?
  21. What steps must I make to adopt Roth 403(b) Contributions?
  22. Can an employees defer some of their accrued vacation and sick pay to their 403(b) account?
  23. Are Employer 403(b) Contributions and/or Employer 457(b) Contributions subject to FICA taxes?
  24. I received a request to provide historical data for an employee, precisely what information should I provide?
  1. Exactly what is a 403(b) Plan?

  2. In public educational organizations like School Districts and Community Colleges, 403(b) Plans generally serve as supplemental retirement savings plans designed to supplement retirement benefits available from State pension plans and Social Security. The IRS provides a Summary of 403(b) Plan Basics page and a 403(b) Plan Brochure for Employees on its website. Many of the topics covered there are treated in even greater detail on this CCC website, whereas some other topics covered there are not applicable to public employers.

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  3. What Form W-2 Codes should be used for 403(b) elective deferrals, Roth 403(b) contributions, employer 403(b) contributions, 457(b) elective deferrals, Roth 457(b) contributions, and employer 457(b) contributions?

  4. The IRS provides the answer to this question on this very important Common Errors on Form W-2 Codes for Retirement Plans web page.

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  5. Is it possible for us to offer a Retirement Incentive Program that avoids payroll taxes and allows participants to defer Federal and State income taxes?

  6. Yes, you may establish a a program under which the Employer makes post-severance 403(b) contributions on behalf of ALL participants. Doing so exempts contributions from payroll taxes (Social Security and Medicare), thus saving both the employee and the employer 7.65% of the deposited amount. Moreover, as long as participants attain age 55 during or before the calendar year in which they sever their employment relationship, upon severance from employment they become eligible for distributions with no early distribution excise taxes, even though they may not have reached age 59-1/2.

    One thing to carefully consider is whether or not the 403(b) accounts into which contributions are deposited impose "early" distribution penalties. These may be avoided by specifying that all contributions will be made to accounts "negotiated" with a vendor that guarantees no vendor-imposed distribution penalties at any time. Alternatively, you may allow participants to select 403(b) vendors eligible to receive contributions in your 403(b) Plan, but warn them about the potential for vendor-imposed "early" distribution penalties.

    Warning: You are not allowed to offer a choice between employer post-severance 403(b) contributions and cash, but there is no reason to do that anyway, because participants that want cash can simply take immediate distributions from their 403(b) accounts, pay Federal and State income taxes, and not be subject to Social Security or Medicare taxes.

    Contact us if you have any questions about these arrangements.

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  7. We are offering an Early Retirement Incentive (ERI) program in which eligible employees may elect a lump-sum payment, a monthly stipend for a specified number of years, or a combination of these two. Do employees who decide to participate have the option to defer any portion of these payments into their 403(b) or 457(b) accounts?

  8. No, ERI stipends are not eligible for 403(b) or 457(b) plan deferrals. If the ERI agreement includes an option to contribute portions of the ERI stipend into a 403(b) or 457(b) account, or if you are informing eligible employees that they may elect to contribute any portion of their ERI stipends into 403(b) or 457(b) accounts, please contact CCC immediately.

    On the other hand, while retiree stipends are not eligible for deferral into 403(b) accounts, compensation paid for services rendered to the District (e.g., pay for coaching, substitute teaching, or part-time employment) IS eligible for deferral into 403(b) accounts, even if the individual in question is not a "regular" employee. Consequently, if the two types of payments are made via separate checks, it should be easy to allow 403(b) deferrals from the earned income check, but disallow such deferrals from the retirement stipend check. However, if both types of payments are made in single checks, then it may be a challenge to set this up properly in Payroll.

    Important Warning: It is unacceptable to establish a policy that makes all individuals receiving retirement stipends ineligible to make 403(b) elective deferrals from earned income, for such a policy would clearly violate the universal eligibility for elective deferrals requirement.

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  9. How does an employer determine if an employee is technically "severed from employment" as it pertains to the 403(b) and/or 457(b) Plan?

  10. CCC has created guidance for employers to determine if an employee meets the criteria to be considered "severed from employment". This document is available here.

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  11. The Salary Reduction Agreement for our District is labeled as "Draft - Not for Current Use". Should I continue to use the form we have used in the past or is an approved format available soon.?

  12. Actually, all this means is that Implementation Steps 10-12 have not been completed. So, your District's CCC Coordinator should login on the CCC website, click on the "Implementation Steps" link in the far-left column of navigation links under the "FOR EMPLOYERS" heading, and review Steps 10-12. Then, click on the "Edit Employer Details" link, click on the "Yes" radio button for "Your Employer's section of the CCC website is now ready for your employees to use ('Yes' removes the yellow 'not approved' banner)?", and finally click on one of the "Save Information" buttons found at the top and bottom of the page. The yellow warning will disappear from all pages of the District's section of the CCC website and the Draft warning will disappear from the Salary Reduction Agreement.

  13. In reviewing our section of the CCC website I notice that the following message is on all of our vendor pages: "This Vendor Page has not been approved by American Century Investments, but the information provided should be useful to you." Is there something we need to do in this regard?

  14. No, there is nothing the Employer needs to do in this regard. However, some background information may help you to understand why these banners appear on most Vendor pages.

    Like Employer authorized users, Vendor authorized users have the authority to manage the content of the Vendor's dedicated pages on the CCC website. However, the dedicated Employer sections of the CCC website have been our highest priority, since that's where employees and administrators of our client Districts go for basic information about their 403(b) Plans [and 457(b) Plans, if CCC provides 457(b) Plan administrative services]. Therefore, we have assigned Employer User logins to at least one CCC Contact from each CCC Full Service Client Employer, and encouraged those Users to review their dedicated section of the CCC website and "launch/approve" it when appropriate.

    Similarly, we are prepared to assign full authority User logins to Vendor contacts upon direction from Vendor home offices, but our efforts to encourage the roughly 150 Vendors associated with CCC Client Employer 403(b) Plans to assign Users and manage content of their sections of the CCC website have lower priority than several other critical CCC projects, including:

    • Employer adoption of 403(b) Plan Documents
    • Development of our Transaction Tracking System
    • Actual processing of transactions (loans, hardship withdrawals, exchanges, rollovers, distributions, QDROs, etc.)
    • Assisting IT staffs and consultants (e.g., CSA for Infinite Visions) as they develop HR, PR, and VR extract utilities for client Employers
    • Upgrading our compliance monitoring systems and procedures to meet the requirements of new Regulations

    Some Vendors have been proactive and have added significant content to their sections of the CCC website, but most have been swamped just trying to properly interpret and implement the requirements of the new Regulations themselves. We wouldn't be surprised if several years elapsed before all of the dust settles and most, if not all, of the Vendor pages are fully populated with content and officially launched/approved by the Vendors. In the meantime, I expect that a good number of the lower participation Vendors will cease their participation in CCC Client Employer Plans, if not the entire 403(b) market.

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  15. We are facing RIF situations. What sort of fact sheet might we include in packets for those affected?

  16. Neither your Employer nor Carruth Compliance Consulting, Inc. (CCC) is qualified or licensed to give financial advice. The information below is provided by CCC based on its understandings of current tax law and IRS rules and regulations. It is important that you consult with your own tax professional before taking any actions based on the information provided below. All statements below are based on the assumption that your employment with the Employer sponsoring your 403(b) Plan will be completely severed during 2009. If your name remains on an active substitute teacher list, then your employment is not considered to be severed by the IRS.

    Distribution Options for 403(b) and 457(b) Accounts Upon Severance from Employment

    403(b) Tax Sheltered Annuity Accounts

    • You may leave your account intact, but of course you will no longer be able to contribute to the account following severance of employment.
    • If you will reach your 55th birthday by December 31 of the year your employment is severed, you may take distributions from your 403(b) account and pay income taxes on the distributed amounts as ordinary income.
    • If you will not reach your 55th birthday by December 31 of the year your employment is severed, you may take distributions from your 403(b) account and pay income taxes on the distributed amounts as ordinary income, but you must also pay a 10% Federal tax under Internal Revenue Code Section 72(t).
    • Irrespective of your age, you are eligible to rollover your account balance into an IRA or other eligible retirement plan in which you are eligible to participate.

    457(b) Deferred Compensation Plan Accounts

    • Irrespective of your age, you may take distributions from your 403(b) account and pay income taxes on the distributed amounts as ordinary income. There is no penalty for taking distributions from 457(b) Plans, but your employment must be severed before you become eligible for distributions.
    • Irrespective of your age, you are eligible to rollover your account balance into an IRA or other eligible retirement plan in which you are eligible to participate.

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  17. How do I handle returned remittance checks from Vendors?

  18. First contact CCC and provide as much information as possible about the reason the remittance check was returned. CCC will attempt to resolve the issue with the Vendor in question and get the Vendor to accept the remittance check and deposit it to the accounts of affected participants.

    However, if it turns out that the Vendor did not accept the remittance check for valid reasons (e.g., the Vendor had not received a required agreement form of some kind, the check was received by the Vendor after a date the Vendor had announced as a deadline date for receiving remittances, or Participants have closed accounts and failed to submit new Salary Reduction Agreements), then one of the following approaches may be used to avoid changing Payroll records and W-2 Forms. CCC recommends that the Employer request Participant approval before adopting any approach.

    Several returned remittance checks have resulted from what we refer to as "Insurance and Sister Mutual Fund Company Combinations," "Portal Arrangements," in which one entity serves as a "mini-common-remitter" for multiple Vendors, or "Misunderstood Vendor Relationships." Examples are:

    • New York Life/Mainstay Funds (Insurance and Sister Mutual Fund Company)
    • Nationwide Insurance/Security Benefit (Portal Arrangement)
    • TDS Group/Security Benefit (Portal Arrangement)
    • ING USA Annuity and Life Insurance Company (Misunderstood to be ING Life Insurance and Annuity Company)

    Remit Returned Amounts To The Same Vendors

    a) Provide explanations to the Participants about why the contributions were returned. Provide copies to CCC so we will have the full story if/when the Participants contact CCC for additional explanations;

    b) Place the returned funds in a suspense account until CCC negotiates with the Vendors and provides the missing agreement forms to the Vendors; and

    c) Remit the returned funds to the Vendors out of the suspense account, but do not indicate any such remittance on the Participants' pay stubs. This approach is equivalent to making "later than usual remittances" of 403(b) deferrals exactly as they appear on the Payroll system.

    Remit Returned Amounts To Alternate Vendors

    a) Provide explanations to the Participants about why the contributions were returned. Provide copies to CCC so we will have the full story if/when the Participants contact CCC for additional explanations;

    b) Place the returned funds in a suspense account until the affected Participants establish accounts with different Vendors holding Active Payroll Slots and submit new Salary Reduction Agreements;

    c) Remit the returned funds to the new Vendors out of the suspense account, but do not indicate any such remittance on the Participants' pay stubs. This approach is equivalent to making "later than usual remittances" of 403(b) deferrals exactly as they appear on the Payroll system; and

    d) It would be ideal if you can correct your remittance systems to indicate the new vendor as the recipient of the remittance check for the affected Participant. Otherwise CCC will make a note of this in its records.

    Send Returned Amounts To Affected Participants

    a) Provide explanations to the Participants about why the contributions were returned. Provide copies to CCC so we will have the full story if/when the Participants contact CCC for additional explanations;

    b) Refund the contributions to the Participants via Accounts Payable, explaining that the Participants must claim these amounts as taxable income on their tax returns, even though their W-2 Forms indicate that the amounts were remitted to 403(b) accounts;

    c) Issue Forms 1099-Misc for the amounts refunded following the calendar year in question, entering the amounts in Box 3 for Other Income. For example, if the remittance returned was out of paychecks for 2008, the Form 1099-Misc should be issued for 2008, such amounts should be claimed as income on 2008 Federal and State income tax returns, and we recommend that the 1099-Misc Forms be distributed as soon as possible after returning the refunded amounts to Participants;

    d) Cancel any further contributions/remittances to the Vendor on behalf of the affected Participants. When the Vendor has vacated the 403(b) market entirely, cancel any further contributions/remittances to the Vendor on behalf of any Employees; and

    e) Send a copy of the 1099-Misc form to CCC, since we need to record that the affected Participant actually did not make contributions for the returned amount.

    Contact CCC if you have questions about these procedures.

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  19. We have received a check from a mutual fund company that may be used to offset Plan expenses. What should I do with this check?

  20. If the amount of the check is "small," our recommendation is to deposit the check in the same account that you use to pay CCC expenses and treat it as an offset to 403(b) plan administration costs. Plan assets can be used to offset set plan-related expenses, so following this approach the check would be counted as a plan asset.

    Also, the regulations for correcting excess deferrals offer guidance that is useful in this case. If the total corrective distribution due a participant is $75 or less, the Plan Sponsor is not required to make the corrective distribution if the reasonable direct costs of processing and delivering the distribution to the participant would exceed the amount of the distribution. Hence, if options to allocate the restitution to participants will require a fee of $150 - $350 versus a restitution amount less than that, clearly the cost of processing the distribution is greater than the distribution itself.

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  21. Some of our Employees have received checks from Vendors that are payable to the Employer. These checks deal with a settlement stemming from an investigation into alleged market timing within the Scudder Family of Mutual Funds. What should I suggest that these Employees do with these checks?

  22. Some of these checks appear to be payable to the Employer with no mention of the Employee, while others appear to be payable to the Employer for the benefit of the Employee. The best information available on this issue may be found on the Deutsche Asset Management Settlement Website Frequently Asked Questions page.

    Portland Public Schools employees should visit Human Resources page on the PPS Inside website for additional information.

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  23. What happens if a substitute teacher or other part-time employee specifies a flat amount to be deferred and doesn't earn enough to make the specified deferral?

  24. The Employer should develop an administrative policy to cover this scenario. The Salary Reduction Agreement states the following on the second page:

    TERMS OF THIS AGREEMENT By signing this Agreement, the Employee agrees to modify her/his salary as specified on the front side of this form. Also, by signing this Agreement, the Employer agrees to contribute the amounts specified to the designated Service Provider(s) on behalf of the Employee, subject to verification that the proposed contributions satisfy all applicable IRC limitations and subject to administrative policies regarding minimum net check amounts.

    So, the Salary Reduction Agreement provides a safeguard for just this type of situation. Our recommendation is that the following policy be adopted by the Employer:

    RECOMMENDED POLICY: If an employee earns enough during a given payroll cycle to 'justify' the deduction specified in the Salary Reduction Agreement, then process and remit the deduction. Otherwise, disallow the entire deduction.

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  25. Someone told me that our policies allowing employees to elect 403(b) TSA contributions in lieu of health insurance premiums is a problem that must be corrected. What's the problem with this?

  26. Private Letter Ruling 9104050 addresses this issue, and the conclusion is that in such arrangements, all employees that DO NOT elect the 403(b) TSA contribution option and ACCEPT the employer's payment of health insurance premiums on the employees' behalf would have those health insurance premiums treated as currently taxable income.

    Please contact CCC immediately if your policies currently include a "403(b) TSA Contribution in lieu of health insurance premiums" option, so we can discuss possible remedies to this 403(b) Plan defect.

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  27. Do we need to notify vendors of our TPA relationship with CCC?

  28. It might not be a bad idea to send such letters to current and former vendors, since obviously it is going to take several months for CCC to synchronize CCC and Vendor systems. It's up to you as to whether or not you send out notices to your vendors. If CCC were in your position, we'd wait to see if any remittances out of 2009 paychecks get returned. If any are returned, we can triage our efforts and work on those first.

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  29. What is the process to add a preferred provider to my employer's list of vendors?

  30. The process for adding a "preferred provider" (our terminology is "Vendor with an Active Payroll Slot") may be found in Section 1.3(b) of your employer's 403(b) Plan Document on the CCC website. To get there, click on Employee Entrance button up top and then your Employer. Then click the green menu item: 403(b) Plan Document.

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  31. Are Life Insurance Policies no longer allowed in 403(b) accounts?

  32. Although life insurance policies are not allowed in 403(b) accounts under the new regulations (except incidentally), such policies existing prior to 1/1/2009 may be maintained if you continue to remit contributions as you did prior to 1/1/2009.

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  33. Does CCC provide financial or investment advice?

  34. No. CCC provides only compliance and plan administration services to its client Employers.

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  35. Where should our employees go for financial or investment advice?

  36. A number of resources are available on the web, but many people have neither the time nor the inclination to investigate these resources. Whatever your employees' preferences, they should check out useful links and the left-hand column of the vendors page of their Employer's section of this website, both for doing their own research and for information on financial planners and investment advisors located in their area.

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  37. Does PERS affect 403(b) or 457(b) contributions of our employees?

  38. The general answer is no. Your employees are allowed to contribute right up to their elective deferral limits into either or both of the 403(b) and 457(b) plans, irrespective of employee and employer PERS contributions.

    The only situations in which PERS contributions impact their ability to contribute to 403(b) and/or 457(b) plans is when their gross salary is fairly low (about $16,500 per year for a single plan or $33,000 per year for both plans during 2009). Since contributions are limited to 100% of compensation, if employee PERS contributions are pre-tax salary deductions, they reduce compensation. Consequently, they reduce the amount employees can contribute to the 403(b) and/or 457(b) plans.

    Important Observation: If your Plan is managed by CCC as a Full Service Client, your employees may request free calculations of their maximum allowable contribution (MAC). They should Contact Us to request their MAC calculations.

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  39. Does CCC participate in Employer Benefit Fairs?

  40. The general answer is no. Our experience has been that since we have nothing to "sell" to employees, they almost never stop by our booth/table when we go to the effort to attend Employer Benefit Fairs. Moreover, we strive to keep our fees as low as possible, and costs associated with travel and staff time for attendance at Benefit Fairs have not been factored into our fees.

    However, if you have a strong desire for CCC to have a presence at your Benefit Fair, let us know and we'll provide an estimate of the costs involved, which would necessarily be charged to your Employer in addition to our contract fees.

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  41. What steps must I make to adopt Roth 403(b) Contributions?

  42. First, you must be sure that your 403(b) Plan Document allows Roth 403(b) Contributions. If it does not, the Plan Document must be amended to all Roth 403(b) Contributions.

    Next, you should contact the Vendor to see if any {Vendor} (for this FAQ we will designate a non-specified Vendor as {Vendor}) forms need to be submitted before {Vendor} will accept Roth 403(b) Contributions.

    Then, add to your Payroll System a new "Vendor Name" for “{Vendor} 403(b) Roth,” being sure to distinguish this "Vendor Name" from the "Vendor Name" you already use for {Vendor} Traditional (tax deferred) 403(b) Contributions. For example, if you currently use "{Vendor} 403(b)" as Vendor Name for Traditional (tax deferred) 403(b) contributions to {Vendor}, then you might use "{Vendor} 403(b) Roth" as Vendor Name for Roth (after-tax) 403(b) contributions. I would even recommend that you begin to use "{Vendor} 403(b) Traditional" or something similar to make the distinction between Traditional and Roth as clear as possible.

    Next, The "Deduction Type" for "{Vendor} 403(b) Roth" should be set to "Not Tax Exempt."

    The remittance details/breakout sent to {Vendor} should distinguish between "{Vendor} 403(b) Traditional" and "{Vendor} 403(b) Roth" contributions.

    If the District is remitting Employer Discretionary, Matching, or Post-Severance 403(b) Contributions to {Vendor}, those should be specified as "{Vendor} 403(b) Employer" contributions in the remittance details/breakout sent to {Vendor}.

    W-2 Form Information:

    "{Vendor} 403(b) Traditional" contributions should be listed in Box 12 with Code E.

    "{Vendor} 403(b) Roth" contributions should be listed in Box 12 with Code BB.

    "{Vendor} 403(b) Employer" contributions should be listed in Box 14 with text "Employer 403(b) Contributions."

    The Vendor Remittance (VR) extract utility used by the District to generate VR Data Files for uploading to the CCC website must be edited to include the new contribution/deduction type to ensure that future {Vendor} 403(b) Roth contributions are included in monthly reports to CCC. This observation also applies to ANY new 403(b) TSA or 457(b) DCP Vendor added to the current list of Vendors holding Payroll Slots.

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  43. Can an employees defer some of their accrued vacation and sick pay to their 403(b) account?

  44. Employees may defer some (up to their annual deferral limits) of their regular pay, accrued vacation and sick pay into their 403(b) account if received by the later of 2 1/2 months from the date of severance or the end of the limitation year (in most cases calendar year) in which the severance occurred. IRS Pub. 4483 contains additional information on this issue.

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  45. Are Employer 403(b) Contributions and/or Employer 457(b) Contributions subject to FICA taxes?

  46. Employer 403(b) Contributions are not subject to FICA (Social Security and Medicare) taxes, because they are considered to be employee benefits. On the other hand, Employer 457(b) Contributions are subject to FICA (Social Security and Medicare) taxes, because they are considered to be (deferred) compensation. There is considerable confusion about Employer Contributions for these very reasons, and we have found that some of our clients have mistakenly treated Employer 457(b) Contributions as not being FICA subject. While this is a payroll issue and not strictly within the purview of CCC services, we would be happy to assist any of our clients to resolve issues involving Employer Contributions to either 403(b) or 457(b) plans.

    Please consult with CCC before finalizing any collective bargaining agreement or employment contract that includes provisions involving 403(b) Tax Sheltered Annuity (TSA) or 457(b) Deferred Compensation Plans (DCP).

    In addition to both employee and employer FICA tax savings (click here for illustrations of FICA taxation of Employer Contributions to 403(b) and 457(b) plans), there are numerous other reasons for employers to make contributions to 403(b) plans, rather than to 457(b) plans, including but not necessarily limited to the following:

    • The $50,000 limit on Employer 403(b) Contributions is significantly higher than the corresponding $17,000 limit on Employer 457(b) Contributions.
    • Depending on optional features in the plan document, 403(b) in-service distributions are allowed after after attaining age 59.5, whereas distributions from 457(b) accounts are not allowed until severance from employment.
    • Again, depending on optional features in the plan document, Employer 403(b) Contributions may be made on behalf of former employees for up to five years after severance from employment.

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  47. I received a request to provide historical data for an employee, precisely what information should I provide?

  48. In order to determine eligibility for the 15 Years of Service Catch-up in 403(b) plans and the 3 Year Catch-up in 457(b) plans, it is necessary to have all historical data for an employee. This information can be provided to CCC in a couple of formats.

    CCC has a "Secure Data Export" feature in the left hand navigation menu for logged-in district administrators to extract a copy of the payroll (PR) and vendor remittance (VR) currently in our system as well as formatted PR and VR data templates that can be filled for earlier years. You will note that the fill-able templates go back to 1960's, simply delete all rows representing years earlier that the participant's hire year. Once completed the files can be uploaded to the employer's Secure Payroll Data folder as you would the monthly compliance files uploaded to CCC.

    If it is not possible to provide historical data to CCC in the PR and VR file formats, there is an alternative. Provide CCC with copies of the participant's W2s back to their hire data or the first year the employer has record of participation in the 403(b) and/or the 457(b) plan. A separate reporting of the employee's annual FTE back to their first year of hire will also be required.

    To gather historical data, employers frequently have to access archives or older software systems. We understand this can take time and occasionally the data may not be available. Whenever CCC has a request to review a participant's data for catch-up eligibility we always let the participant know that gathering the data may take time and the data is subject to availability.

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