Why Catch-Up Contributions Aren’t Part of Actual Deferral Percentage Testing

Retirement planning is a crucial aspect of financial management, and one of the key components is contributing to a retirement savings account. To encourage individuals to save more for their golden years, the Internal Revenue Service (IRS) allows catch-up contributions for those who are 50 years or older. However, it’s important to understand that catch-up contributions are not considered in Actual Deferral Percentage (ADP) testing. In this article, we will explore why catch-up contributions are excluded from ADP testing and how the IRS ensures fairness through non-discrimination tests.

Understanding Actual Deferral Percentage (ADP) Testing

ADP testing is a method used by the IRS to ensure that retirement savings plans, such as 401(k) plans, do not disproportionately benefit highly compensated employees (HCEs) over non-highly compensated employees (NHCEs). The purpose of ADP testing is to prevent discrimination in favor of HCEs and promote fairness among all employees.

During ADP testing, the contributions made by both HCEs and NHCEs are compared to determine if there is a significant disparity. The ADP is calculated by dividing the total contributions made by the HCEs by the total contributions made by the NHCEs. If the ADP of the HCEs exceeds certain limits set by the IRS, corrective measures must be taken to avoid penalties.

Why Catch-Up Contributions Are Excluded

Catch-up contributions are additional contributions that individuals aged 50 or older can make to their retirement savings accounts. These contributions are designed to help individuals “catch up” on their retirement savings if they have not been able to save enough in previous years. However, catch-up contributions are not considered in ADP testing for several reasons.

Firstly, catch-up contributions are subject to their own limits, separate from the regular contribution limits. For example, in 2021, the catch-up contribution limit for 401(k) plans is $6,500, in addition to the regular contribution limit of $19,500. Excluding catch-up contributions from ADP testing ensures that the testing focuses on the regular contributions made by employees, without the influence of catch-up contributions.

Secondly, catch-up contributions are typically made by individuals who are closer to retirement age. These individuals may have higher salaries and more years of service, making them more likely to be classified as HCEs. Including catch-up contributions in ADP testing could potentially skew the results and unfairly penalize employers who have a higher number of older employees making catch-up contributions.

Non-Discrimination Tests for Catch-Up Contributions

While catch-up contributions are not part of ADP testing, the IRS has implemented non-discrimination tests specifically for catch-up contributions. These tests ensure that catch-up contributions do not disproportionately benefit HCEs and comply with the overall goal of promoting fairness among all employees.

The two non-discrimination tests for catch-up contributions are the Actual Contribution Percentage (ACP) test and the Average Contribution Percentage (ACP) test. These tests compare the catch-up contributions made by HCEs to those made by NHCEs, similar to how ADP testing compares regular contributions.

If the ACP or ACP test reveals a significant disparity between the catch-up contributions made by HCEs and NHCEs, corrective measures must be taken to avoid penalties. These measures may include returning excess contributions to HCEs or providing additional contributions to NHCEs to level the playing field.

The Importance of Fairness in Retirement Planning

Retirement planning is a shared responsibility between employers and employees. It is crucial to ensure that retirement savings plans do not discriminate against certain employees based on their compensation or age. By excluding catch-up contributions from ADP testing and implementing non-discrimination tests specifically for catch-up contributions, the IRS ensures fairness and equal opportunities for all employees to save for their retirement.

In conclusion, catch-up contributions are not considered in ADP testing to maintain the integrity of the testing process. However, the IRS has implemented separate non-discrimination tests for catch-up contributions to ensure fairness among all employees. Retirement planning should be inclusive and accessible to everyone, regardless of their age or compensation, and these measures help achieve that goal.