Plan Administration Information
Extension to the Time in Which Funds Must be Used
The timeframe to use forfeiture funds from your DC plan has been extended.
Previously, employers were required to utilize DC forfeiture funds in the plan year in which they occurred. Effective January 1, 2024, the IRS extended the deadline, stating funds must be used no later than 12 months after the close of the plan year in which the forfeiture occurred. This effectively allows an additional year to utilize such funds.
Example: If forfeiture funds are incurred in June of 2024, they would need to be utilized by December 31, 2025.
A few additional things to remember:
- To ensure compliance with this IRS forfeiture funds are not utilized by the required deadline, funds will automatically be distributed as an equal share to any active participant in that DC plan. MERS will begin applying this default in alignment with the revised deadline of December 31, 2025.
- Employers may continue applying funds toward offsetting employer contributions or participant fees. Please reach out to your Benefit Plan Coordinator to request this option prior to the revised deadline.
Using Elapsed Time to Calculate Vesting (Service) for the Defined Contribution Plan (including the DC portion of hybrid)
Unless otherwise adopted by the employer, defined contribution plans earn service based on elapsed time. Elapsed time looks at only the date of hire and date of termination to calculate time toward meeting vesting.
Example: If an employee has a hire date of 10/1/2013 and termination date of 10/5/2014, one year of service is earned toward vesting. If the termination date was 9/15/2014, no service would be earned.
Elapsed time has been applied to all active participant records. Participant who were terminated prior to October 2015 will have service calculated based on when contributions were reported by their employer in each month. When applying service credit from defined contribution to defined benefit, months can still be applied to help a participant reach their defined benefit vesting. When applying service toward a defined contribution record from a defined benefit or another defined contribution plan, all time (by months) will be considered, although only full year increments count to reach vesting.
MERS-to-MERS Service Coordination for Defined Contribution (include the DC portion of hybrid)
Employees who would like to verify MERS-to-MERS time for inclusion in DC service should contact the MERS Service Center at 800.767.MERS (6377) or fill out and submit the MERS-to-MERS Service Verification Form (md-016). MERS-to-MERS time will only apply before a DC distribution is taken or a forfeiture occurs, ensuring that employers will not incur future liabilities.
Any participant who has not met the requirements to become vested in their employer contributions will forfeit non-vested assets after a period of one year or a withdrawal of his or her entire vested account balance has occurred.
Forfeitures are pulled four times per year – February, May, July and November.
Increased Communication on Forfeiture Fund Balances
The Employer Portal will provide alerts when there are forfeiture funds that need to be utilized. In addition, notices will be emailed regularly from our recordkeeper, Alerus, including your forfeiture balance and instructions on how to use the funds. You’ll also receive a quarterly report with an itemized list of forfeiture amounts and associated due dates.
When enrolling an employee in the MERS Defined Contribution Plan, employers should use this quick enrollment form (MD-000) which reduces the amount of information an employee is asked to provide in order to enroll. Additionally this form lessens the amount of time and administrative oversight needed to enroll your employees into the DC plan.
Submitting New Hire Information to MERS
To begin reporting for a new hire, simply add them to your payroll file. For more information on the new hire communication process, select your program and look under the administration section for new hire. Please remind your new hires that they need to complete and submit beneficiary information to MERS as soon as possible. Here is the link to our beneficiary form (form MD-703).