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15-Year Service Catch-up and Nursing Homes

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Can a nursing home 403(b) plan permit participants to make 15-year service catch-up contributions? I don't think they would be considered a home health service agency or health and welfare service agency. Could it be considered a hospital?

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Take a look at 1.403(b)-4(c)(3)(ii)(C)(1). Seems to me that this might be a "gray area." Might also depend upon the type of "nursing home" - for example, if it is just an assisted care facility as opposed to a nursing home that only handles people who need complete care, it might make a difference in the determination. A good way of saying, "I don't know."

I've rarely found that catch-up provision to be worth much, or to be even reasonably workable from an administrative standpoint, due to the data requirements to make the special catch-up calculation. We have just one plan that uses it, and that was only because they insisted. We always go with just the "regular" catch-up.

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