HRagain

Even if you could, I would not suggest it. If you want to allow these ineligibles on the plan, then work with their broker/insurance contract to actually allow that. But they were never really eligible for the plan and not qualified beneficiaries for COBRA purposes. I can't see why the employer after doing an ineligible audit would override this by choosing to extend something they still aren't eligible for! The whole point is to get ineligibles OFF the plan immediately

I'll be really honest. I hate 1 year eligibility. I dislike 6 months. Even if there is a safe harbor contribution. I'd be curious if the plan has SH vs match with a vesting schedule/forfeitures for early turnover. Even if there is high turnover, I still wouldn't suggest much more than a 3 month. This last job I had to wait to 1st day after 6 months, so I started as close to the end of the month as possible to be eligible that much earlier. I guess I'd ask the business reason to keep it at 1 year eligibility at all rather than making an exception for one employee. Does the employer have a problem passing nondiscrimination testing if not SH? So I understand it can definitely depend on the industry/employee pool. That said, have there been other complaints about waiting that long to start? If not changing for all, I agree with a bonus or other perks.

I would agree with you. If the internal plan administrator can't handle these, TIAA isn't going to have the access or ability or want to check balances. They might send a report to the internal admin who would be able to say yes/no to the cashouts, but I suspect this could be a very easy mistake to make.

Glad to be back though under another name because I've switched employers a few times and I totally forgot my old username, but I know this is at least a 3rd one *Ü*. I am NOT the plan administrator here, but have 25+ years (back to the non-mutual fund quarterly stone age on recordkeeping of 401ks). I have not kept up 100% with what type of corrections are required, so bear with me on these details. Sorry this one is a little long! Participant became eligible to participate on 11/1/25. Participant chose 6% Pretax Deferral that came with 4.5% Employer Match (with a 5 year cliff vesting schedule) along with receiving a 3% Safe Harbor contribution each pay period (there were 4 left in 2025). Each pay period had the same amount of Plan Eligible Compensation (basically gross salary without bonus or GTL imputed income) and the same amount of deferrals and contributions. When compliance tests were run, somehow the recordkeeper forfeited a small amount of Employer Match and Safe Harbor for 2 employees (the other was eligible on 3/1). One of them being myself. I only noticed when I went into the employer system on 5/6/26 and saw 2 (albeit small) withdrawals on 4/13/26. I requested an explanation from our internal plan administrator (who reviewed the compliance process/testing and reports and approved these withdrawal/forfeitures) and got told to "reach out to the recordkeeper for clarity. There is nothing we in (dept) effectuated here." I spent 2.5 hours on the employer's site and speaking with 3 people at the recordkeeper (that I have access to since I am the HR Manager and know a lot about benefits, etc. My CEO agreed to that access when I started although I play no part in recordkeeping/auditing/etc) So I dug...of course I did LOL! I found that both withdrawals were forfeited amounts plus associated earnings, which was odd since the contributions exactly matched the calculations against my pay each pay period that came from payroll to the recordkeeper. I also found the confirmation form where the department approved these withdrawals the same day they got the compliance report (so no one in that dept questioned it then). I then figured that it had to be based on eligible pay being somehow incorrect. So I sent that department another email with my findings an got told "It does stink that money is taken from us". I had to escalate this to my CEO with the threat of a formal DOL participant request for the CEO to go back to this department head to actually have them review anything. And lo and behold the eligible pay was incorrect. Shock, I know! They claimed they did full year pay and subtracted out 9 months from a prior pay system (which had its own issues) and then 1 extra month's pay to get to 11/1. Not sure why they didn't just add up the 4 pay periods that counted as eligible 401k plan compensation. A few employers ago, I had 3 eligible compensation calculations depending on employee service with at least 2 changing on their anniversary date. In the end, on the 5/15/26 payroll submission, that dept added those two amounts in with current SH and ERM (such that now payroll doesn't match the recordkeeper for 2026 and these two will be overstated in the 2026 compliance records or at least won't match between payroll and the recordkeeper). And I didn't get the miniscule interest back nor interest from 4/13 to 5/15. Not that it would be much. In the end, my question is did something change on how corrections are completed? Is this now how "corrections" are done? Would it not be "cleaner" to have the recordkeeper reverse the two participant ERM/SH forfeitures and put the earnings back at least for that time period? Because it still shows as a forfeited withdrawal on 4/13 and an increased contribution for 5/15.... That said, neither of the two participants received the letter(s) from the recordkeeper nor did the dept even tell us that they had approved these (albeit small) withdrawals. So had I not been vigilant I think it never would have been found! Am I wrong to think (1) it should have been communicated when approved to withdraw - wouldn't most internal plan administrators give the employees a heads up and (2) I should have gotten the original earnings back along with another month's earnings? I'm not going to press the 2nd but wanted to confirm my thought process. How come crazy things always seem to happen to be something I find (this isn't the first with payroll/the old payroll system and my own personal information - not as HR Manager)?