"Plan Sponsors that do not want to add a Roth provision to their plan do not need to do so, nor do they need to stop permitting catch-up contributions. However, only non-HPIs would be able to make catch-up contributions under such plan.... Plan Sponsors will need to monitor who is an HPI and ensure that they are not permitted to defer more than the deferral limit ... A plan can provide that, in the absence of an affirmative election to the contrary, HPI participants will be deemed to have irrevocably elected that their catch-up contributions will be Roth.... There are three ways in which a Plan Sponsor may correct an HPI's pre-tax catch-up contributions."  MORE >>