2020 Electronic Compliance Edge® materials
With the uncertainties surrounding schools reopening for the Fall due to COVID-19, TSACG would like to help make distribution of your 2020 Annual Retirement Benefits Guide easy and efficient by providing generic electronic materials for you to forward to your employees either via email or Intranet/Employee Portal posting. This electronic method provides an easy solution without the need for manual person-to-person distribution of materials this year. Below is our standard information to assist with this distribution:
Attached are electronic copies of TSA Consulting Group, Inc.’s (TSACG) 2020 Annual Retirement Benefits Guide (ARBG) and 403(b) Meaningful Notice/Plan Information brochure. These electronic versions of our ARBG and 403(b) Meaningful Notice are provided to (St. Ignace Area Schools, Eastern Upper Peninsula ISD, MI) as requested, in lieu of or in addition to printed materials, for posting on the District’s internal Intranet site as well as emailing to District employees. Please note that TSACG does not authorize posting of this electronic document on the Internet, and TSACG retains all Copyright authority governing this document.
IRS regulations state that, “The universal availability requirement of section 403(b)(12)(A)(ii) provides that all employees of the eligible employer must be permitted to elect to have section 403(b) elective deferrals contributed on their behalf if any employee of the eligible employer may elect to have the organization make section 403(b) elective deferrals.” The position of TSACG is that all employees, regardless of status (full or part-time) are eligible to participate in the 403(b) plan. In other words, any employee with wages reported on a W-2 should be considered eligible to make elective deferrals into a 403(b) account under the plan. Please be advised that school board members and/or trustees continue to be ineligible under IRS rules. While it is true that current regulations allow a Plan Sponsor to exclude employees that normally work less than 1000 hours per year based upon each of the trailing 12 month periods beginning on their hire date, we do not recommend using this exclusion due to the inherent liability of miscalculation in future years and subsequent penalties for operational failures.
The IRS rules require Plan Sponsors to notify employees annually of their eligibility to participate in the 403(b) plan. There is no set standard for this notification but it is logical to assume that full compliance with this requirement is dependent upon the ability to demonstrate that ALL eligible employees (full and part-time) have equal access to the information provided concerning the plan. Electronic communication via e-mail and/or Web-based materials may not be adequately accessible by some eligible employees. For this reason, the position of TSACG is that the Plan Sponsor should follow the steps below when utilizing electronic materials.
- An ARBG should be emailed to all employees with access to the District’s email system.
- A record of the email distribution list should be retained each year.
- Printed materials should be maintained for distribution to those employees who do not have access to the District’s email system and for inclusion in new hire/substitute packets. You may use the attached 403(b) Meaningful Notice for this purpose.
- The electronic ARBG should be placed on the District’s intranet site in an area commonly known to house benefits information.
Should you have any questions please do not hesitate to contact us.
30 Ferry Road SE, Unit B, Fort Walton Beach, FL 32548
Toll Free: 1.866.569.9967
The information and/or attachment contained in this email is confidential and should only be read by the individual or representatives of the client employer. TSA Consulting Group, Inc. retains copyright authority to all written materials and such materials should not be dispersed to others or posted on the Internet without the expressed written permission of TSA Consulting Group, Inc., 15 Yacht Club Dr. NE, Fort Walton Beach, FL 32548