UWRP and VIP compliance review and FAQ
Last updated: September 26, 2023
In autumn 2021, UW Internal Audit began a compliance review of participant contributions made to the UW Retirement Plan (UWRP) and Voluntary Investment Program (VIP) for Plan Years 2017 through 2021. Internal Audit completed its work on June 13, 2023.
Based on an analysis of the data to date, the University determined that approximately 205 UWRP/VIP participant accounts experienced an operational issue in one or more Plan Years 2017-2022.
The types of issues determined by the compliance review include:
- Participant contributions exceeded the elective contribution limit contained in Section 402(g) of the IRS Code in one or more tax years and require correction by the University.
- Participant contributions exceeded the annual additions limit contained in Section 415 of the IRS Code in one or more tax years and require correction by the University.
- Participant was in a group subject to the Section 401(a)(17) compensation limit contained in the IRS Code and your contributions were calculated in one or more tax years with respect to eligible compensation exceeding limit and require correction by the University.
- Participant was in a group exempt from the Section 401(a)(17) limit, but your contributions were limited and corrective contributions from the University are required.
The following FAQs will be updated as more information becomes available
Q. How were participants notified of the issues?
Impacted participants were initially notified by letter to their home address as listed in Workday on July 19, 2023.
Q. What does it mean if I didn’t receive a notification letter?
Additional analysis continues, including for Plan Year 2022, and you will be notified in the future should the University determine that your UWRP/VIP account is affected. If you believe your account was affected or you should have received a notification, please contact firstname.lastname@example.org.
Q. I received a notification letter. What happens next?
Starting in late September, the University will begin sending letters to each individual by US Mail describing each issue impacting their account and explaining how the issue was corrected.
Q. How will corrections be determined?
All corrections will be made in accordance with the IRS Self-Correction Program found in Revenue Procedure 2021-30, as amended by Secure Act 2.0. The IRS Self-Correction Program is well-established guidance published by the IRS that plan administrators use to correct certain commonplace operational issues. The UW record keepers, Fidelity and TIAA, will complete all necessary corrections and you will receive a notice by U.S. Mail informing you of each correction made to your account and providing you an opportunity to request a hearing to review the correction decision and result.
Q. Are there other possible types of corrections other than those included in Internal Audits original compliance review?
To ensure thoroughness of our review data analysis continues and, if additional issues requiring correction are determined, the affected participants will be notified. We expect to complete this additional review by the end of Plan Year 2023 and will determine whether additional action is needed and, for each instance, will notify any affected participants at that time. Separately, and beginning with the current plan year, 2023, the University will begin conducting annual limit testing as part of an enhanced retirement plan compliance program. More information will be posted as it becomes available.
Q: Where can I ask questions about the corrections described in the notice I received?
If you have questions about the corrections or adjustments to your account or would like help understanding what is described in your notice, you can may contact the UWHR Benefits team at email@example.com or 206-543-4444. For general information about the UW retirement plans and guidance on managing annual contributions in compliance with IRS limits, please visit UW Benefits Retirement Plans.
Q: How can I get assistance with my accounts or schedule a consultation with an approved financial advisor?
To access resources, schedule a 1:1 consultation with a TIAA or Fidelity Workplace Financial Consultant, or get assistance with your accounts, visit the UW Fidelity homepage. For general information about the UW retirement plans and guidance on managing annual contributions in compliance with IRS limits, please visit UW Benefits Retirement Plans.