Best Practices for 403(b) Plans

The Plan Sponsor Council of America’s (PSCA’s) last 403(b) Survey found 403(b) plans were still catching up with retirement plan best practices, Brad Holterhaus, director of Tax-Exempt Markets at Principal, told a group of attendees of the PSCA’s 69th Annual Conference.

Overall, Principal suggests plan design best practices:

• Automatically enroll participants at a deferral of 6% of salary (While more than half of 401(k) plans auto enroll participants, only 16% of 403(b)s do, the PSCA survey found);
• Automatically escalate deferrals each year up to 10% of salary;
• Do a re-enrollment to sweep in all employees not participating or not participating at a 6% deferral rate;
• Choose an appropriate qualified default investment alternative (QDIA) for the plan; and
• Stretch the match to get employees to save more.

Holterhaus clarified that his discussion was about Employee Retirement Income Security Act (ERISA)-governed 403(b) plans.

Other plan design best practices include streamlining the plan’s investment lineup. Holterhaus noted that the average number of options in 401(k) plans is 19, while the average in 403(b) plans is 29—and the average is 43 for plans in the 1,000 or more participants range.

Using a single recordkeeper can also help streamline the plan and its administration. “About 83% of 403(b)s have moved to a single provider, and we expect that trend to continue,” Holterhaus said.

He suggested a retirement plan adviser can help 403(b)s with plan design and recordkeeper selection, and he shared a case study providing an example about how advisers can help. Holterhaus said one plan sponsor didn’t like its current recordkeeper, but it didn’t know what to do about it. The plan’s payroll provider suggested the plan sponsor freeze the 403(b) and adopt a 401(k) plan instead. Now the plan sponsor has two plans to administer and for which it has to file a Form 5500. Holterhaus told conference attendees an adviser would have led them differently by doing a request for proposals (RFP). He also suggested that best practice is to do an RFP to at least benchmark providers every three to five years.

He noted there are fewer providers in the 403(b) space than in the 401(k) space. Plan sponsors should make sure the provider knows the tax-exempt market, has the technology and investment options needed for plan administration and design, provides participant education, and can administer other plan types such as defined benefit plans and non-qualified plans.

NEXT: Fiduciary best practices

Since passage of 403(b) regulations in 2007, 403(b) plan sponsors have been getting a grip on their fiduciary responsibilities, but many are still falling behind. Of non-profit organizations that sponsor 403(b) retirement plans, 60% are reviewing and evaluating the investment options in their plans themselves, according to the latest 403(b) Snapshot Survey from the PSCA and sponsored by the Principal Financial Group.

Holterhaus said the best practice is to have an investment expert review and monitor investments. He also suggested that having an investment policy statement (IPS) in place and following it is a best practice. He noted that half of 403(b) plan sponsors surveyed indicated either they do not have an IPS or they are unsure if they do.

The good news is more 403(b) plans are doing quarterly and semi-annual investment monitoring rather than annual or less frequent.

Holterhaus said the number of 403(b) plans being audited is up about 8% to 10%. He suggested plan advisers can help plan sponsors with compliance and fiduciary responsibility, providing another case study. A 403(b) plan sponsors filed a Form 990, required by non-profits, which indicated it provided an employer match to employees in its 403(b) plan. However, the plan had not filed a Form 5500, so that sent up a red flag to the Internal Revenue Service (IRS). The plan also had no plan document, something required of 403(b)s since 2009. The plan sponsor hired an adviser who helped it get a plan document in place and correct compliance errors with the IRS. Holterhaus said, with the adviser’s help, the plan sponsor paid no fines or penalties and it didn’t have to go back and correct for prior years.

Providers can also help 403(b) plan sponsors with fiduciary responsibilities, Holterhaus noted. For example, Principal offers a fiduciary document catalog and a fiduciary activity log report.

Holterhaus concluded by telling conference attendees they should be measuring plan success by the retirement readiness of participants. He noted that many retirees who work later say they do so to keep employer-sponsored health care. Older employees are more expensive to employers. While it is still good to measure plan participation and participants’ savings rates, the true measure of success is how many participants are on track to replace a certain percent—70% to 80%—of income in retirement.