Art of the Qualified Plan Audit

Knowledge is Power Plan sponsors should strive to prevent plan operational mistakes by training their plan officials to recognize the relevant risks and to have a heightened awareness of the potential for error in each area including eligible compensation, participant eligibility, contribution calculations, missed required distributions, incorrect or ineligible distributions, failure to use forfeitures, and … Continued

Forfeitures are a routine, but often misunderstood, feature of all qualified retirement plans. While they may seem like a minor administrative detail, how forfeitures are handled can directly impact employer contribution costs, participant balances, and overall plan compliance. Recent regulatory attention has also made forfeitures a renewed focus area for the DOL and the IRS. … Continued

Long-term, Part-time employees became eligible for the first time in 2024 for for-profit corporations and in 2025 for nonprofit corporations. 403(b) plan sponsors’ auditors will request backup for LTPT employee identification, eligibility, and their effective opportunity to defer during next year’s audits. This blog will explain the rules and the best practices for employers challenged … Continued

This blog was updated 12.19.2025 with enhanced examples.  Background Effective January 1, 2026, catch-up eligible participants who are High Earners must make catch-up contributions on the Roth basis. The industry has been using the term Highly Paid Individuals, so we will use both terms for the sake of clarity and consistency with other published articles. … Continued

Much like our celebratory moment on the field last summer — when our firm’s softball team stepped up to the plate and swung for the fences to clinch the 2025 local accounting-firm championship — retirement plan limits are stepping up in 2026 to keep the retirement-plan game moving forward. The Internal Revenue Service has announced … Continued

In Summary Mandatory Roth Contributions for High Earners: Effective January 1, 2026, “High Earners” (defined as participants with prior-year FICA wages exceeding $150,000) are required to make all catch-up contributions—including the new “Super Catch-Up” for participants aged 60–63—on a Roth (after-tax) basis. Exclusions and Plan Limitations: The mandate strictly applies to employees with W-2 FICA … Continued

In Summary Final Form 5500 Filing, Asset Distribution, and Legal Title: A plan’s final Form 5500 filing obligation is triggered not by the effective date of termination, but by the complete distribution of all assets. In a merger, the final filing is determined by the date the legal title of the assets transfers to the … Continued

In Summary The New Program: There is a new Self-Correction Component (SCC) of the Voluntary Fiduciary Correction Program (VFCP), which allows plan sponsors to officially use the DOL’s online calculator for self-correction. This new option is only available for specific errors, such as delinquent contributions deposited within 180 days where the associated lost earnings are … Continued

In Summary Unclear Deadlines for 401(k) Deferrals: The Department of Labor (DOL) regulations for 401(k) deferral deposits are unclear, using “earliest” and “reasonably” rather than a firm deadline. While small plans (under 100 accounts) have a 7-day safe harbor, large plans do not. As a result, many large plans adopt a 3-day industry standard, which … Continued

In Summary Counting All Roth Dollars: All Roth contributions a High Earner makes count toward the mandate, regardless of when they are made. This means a participant who contributes a portion of their regular 402(g) limit on a Roth basis might already satisfy the catch-up requirement before their total contributions exceed the 402(g) limit. Plan … Continued