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A reviewer opens a 403(b) plan document, sees a clean reference to the minimum distribution rules, and starts marking every box Yes. Then the determination stalls, because Form 15417-E asks you to pick one compliance pathway and cite the exact plan provision that supports each item, and a plan that incorporates the rules by reference under Section I does not also need the alternative language in Section II.
This is the IRS 403(b) Required Minimum Distributions Worksheet 9A (Rev. 4-2023, Catalog No. 94033Z), a checklist a reviewer completes rather than a return a taxpayer files. Read the plan against IRC 401(a)(9), settle which of the three pathways applies, and give every Yes, No, or N/A mark a Plan Reference so the file holds up.
Key Takeaways
- Form 15417‑E is an official IRS form, the 403(b) Plan Required Minimum Distributions Worksheet 9A (Rev. 4-2023, Catalog No. 94033Z). It is a determination checklist a reviewer completes, not a return a taxpayer files.
- The worksheet confirms a 403(b) plan document includes some form of the IRC 401(a)(9) minimum distribution requirements. No 403(b) plan is exempt; the rules reach 403(b) arrangements through the 403(b) regulations.
- It offers three alternative compliance pathways across four Yes, No, or N/A items: Section I (Incorporation by Reference, items a and b), Section II (Alternative 401(a)(9) Language), and Section III (Governmental Plans). A plan qualifies under exactly one.
- Sections II and III are reached only if the plan does not incorporate by reference under Section I. Section III applies to governmental plans only.
- Every item must be marked Yes, No, or N/A with a Plan Reference citation, and any No answer must be explained in the space provided.
What Form 15417-E Does, In Plain Terms
Form 15417-E is the one-page worksheet a reviewer uses to determine whether a 403(b) plan document satisfies the IRC 401(a)(9) minimum distribution rules (per IRS Form 15417-E, Rev. 4-2023, Catalog No. 94033Z). It is a determination checklist, not a taxpayer return, and it has no filing deadline of its own.
- It confirms one thing: that the plan document carries some form of the 401(a)(9) required minimum distribution requirements.
- It applies to 403(b) plans only, not to 401(a), 401(k), or IRAs.
- It runs four Yes, No, or N/A items across three alternative compliance sections, and each item carries a Plan Reference column.
The worksheet states plainly that all plans are required to include some form of the minimum distribution requirements of 401(a)(9). So the first job is not to grade the language; it is to find it in the plan and decide which of the three sections the plan relies on.
The Three Compliance Pathways
The worksheet lays out three acceptable ways a 403(b) plan can satisfy 401(a)(9). They are alternatives, not a cumulative test. A plan qualifies by meeting exactly one.
- Section I, Incorporation by Reference – the plan incorporates the 401(a)(9) requirements by reference. This section has two items, a and b.
- Section II, Alternative 401(a)(9) Language – used only if the plan does not incorporate by reference. One item, a.
- Section III, Governmental Plans – for governmental plans that did not incorporate by reference, a relaxed standard. One item, a.
How To Route A Plan To One Section
Start with Section I. If the plan incorporates 401(a)(9) by reference, you work Section I and mark Sections II and III N/A. If it does not, you move to Section II for a non-governmental plan, or Section III for a governmental plan.
Why It Is Never All Three
From my side of the desk, the most common structural error is trying to satisfy all three sections. Sections II and III are conditional; both begin with "if the plan does not incorporate by reference as provided in Section I above." Identify the single pathway and stop.
Section I, Incorporation By Reference
Section I is the cleanest path and the one most prototype plans use. It has two items, and both have to hold.
Item a, The Incorporation Language
Item a asks whether the plan provides that it will comply with the minimum distribution requirements of 401(a)(9) and the regulations thereunder, in accordance with the terms governing each investment arrangement, unless and to the extent otherwise permitted by law and in regulations or other rules of general applicability published by Treasury or the IRS.
- The carve-out matters. Language that stops at "401(a)(9) and the regulations" and drops the "unless and to the extent otherwise permitted by law" clause is incomplete.
- That carve-out is what lets later Treasury or IRS guidance permit alternative approaches without breaking the plan.
Item b, Each Arrangement Treated As An IRA
Item b asks whether, for purposes of applying the 401(a)(9) distribution rules, the plan treats each investment arrangement as an individual retirement account or annuity (IRA), with distributions made in accordance with Treas. Reg. 1.408-8, except as provided in 1.403(b)-6(e).
Quick rule you can copy into your SOP: a 403(b) plan is not a single account for RMD purposes. Each investment arrangement is treated individually, more like an IRA than a 401(k) account.
Section II, Alternative 401(a)(9) Language
If the plan does not incorporate by reference, Section II asks whether the plan instead provides language that complies with 401(a)(9), the regulations 1.401(a)(9)-1 through 9, and Treas. Reg. 1.408-8, except as provided in 1.403(b)-6(e).
- Both pieces are required: the 401(a)(9) regulatory standard and the 1.408-8 IRA-distribution overlay, subject to the 1.403(b)-6(e) carve-out.
- Language that covers 401(a)(9) but omits the 1.408-8 overlay fails item a.
For the detailed plan requirements behind this language, the worksheet points you to Worksheet 9 in IRS Publication 7004. Check the draft against that before you mark Section II.a a Yes.
Section III, Governmental Plans
Section III applies only to governmental 403(b) plans that did not incorporate by reference. It asks whether the plan provides a reasonable and good faith interpretation of 401(a)(9).
- This is a relaxed standard. Governmental plans are not held to the full Section II regulatory-language test.
- Applying Section II to a governmental plan overstates the requirement; applying Section III to a non-governmental plan understates it.
So confirm governmental status before you reach for Section III. Status drives which standard the plan has to meet.
The Plan Reference Column And The Yes, No, N/A Marks
Each item has a Plan Reference column plus Yes, No, and N/A response columns. The marks are simple; the discipline is in the citation.
- A Yes generally indicates a favorable conclusion is warranted. The instructions say "generally indicates," so treat it as presumptive, not a guaranteed pass.
- A No indicates a problem exists, and it must be explained in the space provided in that section.
- N/A is the right mark for a section the plan does not use; leaving an item blank is not.
For every item, record the plan-document section that supports the answer in the Plan Reference column. A blank reference is the most common reason a Worksheet 9A file comes back for rework.
Building A Worksheet 9A Review File
Think like the reviewer who reads the next file after yours. They want the plan name, the controlling citations, and a clear single-section conclusion. Give them that path.
- Enter the name of the plan at the top of the worksheet before anything else.
- Confirm the document actually contains 401(a)(9) language; no 403(b) plan is exempt.
- Decide the one section that applies, then mark the other sections N/A.
- Cite a plan-document section in the Plan Reference column for each item.
Small errors create big cleanup. A worksheet that ties each item to a named plan provision moves; one that leaves references blank bounces back.
Documentation Traps That Stall A Determination
These are the recurring gaps my team watches for on Worksheet 9A.
Missing Carve-Out Language
Section I.a incorporation language that drops the "unless and to the extent otherwise permitted by law" clause is incomplete. Paste the full carve-out into the plan.
Single-Account Treatment
Treating the 403(b) plan as one account for RMD purposes contradicts item b, which treats each investment arrangement individually under 1.408-8. Fix the plan language, not the worksheet mark.
Section II Without 1.408-8
Alternative language that covers 401(a)(9) but omits the 1.408-8 overlay fails Section II.a. Cross-check against Worksheet 9 in Publication 7004.
Where Accountably Fits
Most teams do not struggle for lack of work; they struggle with review capacity. If your group runs 403(b) plan-document reviews and the determination work piles up, you can standardize how Worksheet 9A is completed without adding burnout. When we step in, we do not drop random resumes into your inbox. We plug trained offshore accountants into a structured workflow with SOPs, standardized workpapers, checklists, and review protection. You stay in your own systems, with your own templates, and you get predictable turnaround without losing control.
- SOP-driven execution, so every worksheet follows the same steps.
- Structured workpapers and naming logic, which make reviews faster.
- Layered quality checks, so senior reviewers spend less time in the weeds.
If you already have a process, we follow it. If you need one, we can help you build it. This is capacity with control, not chaos.
Watch For Changing Guidance
The worksheet itself states that the technical principles in it may be changed by future regulations or guidelines. The 4-2023 revision is current, but it is not locked law.
- Subsequent IRS guidance, including SECURE 2.0 implementation regulations, may modify the RMD principles.
- Re-confirm current guidance before you rely on a conclusion drawn from an older review.
From my side of the desk, this is the line people skip. A clean worksheet from two years ago is a starting point, not a permanent answer.
What A Finished Worksheet Looks Like
A complete Worksheet 9A has the plan name at the top, one section worked and the others marked N/A, a Plan Reference for every item, and a written explanation under any No answer.
| Element | What good looks like |
| Plan name | Entered at the top of the worksheet |
| Section choice | Exactly one of I, II, or III worked; others N/A |
| Plan References | A document citation for every answered item |
| No answers | Each one explained in the space provided |
That is the file a reviewer can accept without a second pass: one clear pathway, every item supported, every problem explained.
Common Mistakes To Avoid And Best Practices
The same handful of errors stall 403(b) plan-document reviews every cycle, and most trace back to misreading how Worksheet 9A is structured. Here is what my team watches for when we work Form 15417-E.
The Delivery Reality For Teams
If your group runs 403(b) plan-document reviews and the team is swamped, the bottleneck is rarely the worksheet itself. It is review loops, unstructured workpapers, and inconsistent timelines that eat senior hours and create deadline risk. When you must work many of these reviews, treat them as operations, not one-off favors. Standardize the build, centralize templates, and install a multi-layer review that catches the missing carve-out or the blank Plan Reference before it reaches a senior reviewer.
Accountably integrates trained offshore teams into your systems, with your templates and naming, so review production is predictable. This is not resume farming. It is SOP-driven work, checklists, structured workpapers, turnaround SLAs, and continuity plans so nothing stalls if someone is out. Use us when you need capacity without chaos, and keep control of your workflow, security, and quality.
Form 15417-E, Quick Builder Checklist
- Enter the name of the plan at the top of the worksheet.
- Confirm the plan is a 403(b) arrangement and that it includes some form of the 401(a)(9) requirements.
- Decide the single section that applies: Incorporation by Reference (I), Alternative Language (II), or Governmental (III).
- For Section I, confirm item a carries the full carve-out clause and item b treats each investment arrangement as an IRA under 1.408-8.
- For Section II, confirm the language covers 401(a)(9), regs 1.401(a)(9)-1 through 9, and 1.408-8, cross-checked against Worksheet 9 in Publication 7004.
- For Section III, confirm governmental status and a reasonable, good-faith interpretation of 401(a)(9).
- Mark every item Yes, No, or N/A, record a Plan Reference for each, and explain any No answer.
- Re-check for newer guidance, such as SECURE 2.0 changes, that may modify the principles.
If your team works many of these, turn the checklist into an SOP with standard file names and a two-step review. That single change cuts senior-reviewer time sharply.
Security, Privacy, and Work Integrity
- Treat plan documents and participant data as confidential; limit access to the staff who need it.
- Store all files in a secure folder with role-based access, audit logs, and a zero local storage policy.
- Keep originals in a secure repository, and maintain a complete record of the plan versions and amendments reviewed.
- Record which section was worked and which plan provision supported each item, so the worksheet is traceable.
- For team reviews, log who prepared, who reviewed, and when, so the audit trail stays complete.
For Teams That Need Scale Without Chaos
If you have more determination work than hands, the fix is structure, not heroics. Create SOPs, standard workpapers, and a layered review so every Worksheet 9A follows the same path and nothing depends on one person's memory. If you choose to extend your capacity, Accountably plugs trained offshore teams into your systems with clear SLAs, quality checks, and continuity plans. You keep control of workflow, security, and standards while your senior reviewers get hours back.
Conclusion
You do not need to memorize the regulations to get this right. Enter the plan name, confirm the plan carries 401(a)(9) language, then pick the one section that applies. For Section I, hold the full carve-out and the IRA-style treatment of each investment arrangement. For Section II, keep the 1.408-8 overlay. For a governmental plan, apply the reasonable, good-faith standard under Section III.
Cite a plan provision for every item, explain every No, and re-check current guidance before you rely on an older conclusion. If you want help turning this into a firm-wide standard, Accountably can build the discipline around your plan reviews and delivery so your team stops firefighting and starts scaling with confidence. Either way, you now have the playbook.
Reusable Checklists
These checklists are copy-paste ready for your plan-review SOPs. Drop them into your workpaper template so every Form 15417-E review follows the same path.
403(b) RMD document review
- Enter the plan name at the top of the worksheet.
- Confirm the arrangement is a 403(b) plan, not a 401(a), 401(k), or IRA.
- Locate the plan provision that addresses minimum required distributions and note its citation in the Plan Reference column.
- Verify the plan includes some form of the IRC 401(a)(9) minimum distribution requirements.
- Decide which single compliance section applies: I, II, or III.
- Mark every item Yes, No, or N/A; leave none blank.
- Write an explanation under any “No” answer in the space provided.
Section I incorporation-by-reference check
- Confirm Section I.a language states compliance with 401(a)(9) and the regulations thereunder.
- Confirm the language ties compliance to the terms governing each investment arrangement.
- Confirm the carve-out clause: unless and to the extent otherwise permitted by law and IRS or Treasury rules.
- Confirm Section I.b treats each investment arrangement as an IRA for distribution purposes.
- Confirm distributions follow Treas. Reg. 1.408-8, except as provided in 1.403(b)-6(e).
- Record the plan-document citation supporting each item.
Section II or III pathway check
- Use Section II only if the plan does not incorporate by reference under Section I.
- Confirm Section II.a language complies with 401(a)(9), regs 1.401(a)(9)-1 through 9, and 1.408-8.
- Cross-check alternative language against Worksheet 9 in IRS Publication 7004.
- Use Section III only for governmental plans that did not incorporate by reference.
- Confirm a governmental plan provides a reasonable, good-faith interpretation of 401(a)(9).
- Re-check for newer guidance, such as SECURE 2.0 changes, that may modify the principles.
Keep 15417-E Season From Stalling
403(b) plan-document review rarely stalls because Worksheet 9A is long; it stalls because one single-page form holds three different compliance pathways and a stack of cross-references. A reviewer has to read the plan against IRC 401(a)(9), Treasury Regulations 1.401(a)(9)-1 through 9, and the IRA-style distribution rules of Treas. Reg. 1.408-8, then settle on the one section that actually applies.
The fix is not more reviewers; it is a documented workflow that turns the worksheet into a repeatable checklist. When the Plan Reference citations, the section logic, and the explanation blocks are standardized, a “No” answer becomes a tracked action item instead of a stalled file.
- Capture the plan name and the controlling plan-document citation for every item before review starts.
- Route each plan to exactly one section: Incorporation by Reference (I), Alternative Language (II), or governmental interpretation (III).
- Flag any Section I.a language missing the “unless and to the extent otherwise permitted by law” carve-out.
- Confirm Section II alternative language carries the 1.408-8 overlay, cross-checked against Worksheet 9 in IRS Publication 7004.
- Log every “No” answer with its written explanation so the audit trail stays complete.
This is the kind of structured, checklist-driven review our teams run every day. When a group needs documented 403(b) compliance review without adding headcount, our tax services bring the SOPs and multi-layer review that keep determination work moving.
FAQs
What is Form 15417‑E used for?
Form 15417-E is the IRS 403(b) Plan Required Minimum Distributions Worksheet 9A (Rev. 4-2023, Catalog No. 94033Z). A reviewer uses it to confirm that a 403(b) plan document satisfies the minimum distribution rules of IRC 401(a)(9). It is a determination checklist, not a return a taxpayer files, and it has no filing deadline of its own.
Are 403(b) plans exempt from 401(a)(9)?
No. All 403(b) plans must include some form of the IRC 401(a)(9) minimum distribution requirements. The rules apply to 403(b) arrangements through the 403(b) regulations, even though a 403(b) plan is not a 401(a) qualified plan.
Does a plan have to satisfy all three sections of the worksheet?
No. The three sections are alternatives. A plan qualifies under exactly one: Incorporation by Reference (Section I), Alternative 401(a)(9) Language (Section II), or, for governmental plans, a reasonable good-faith interpretation (Section III). Sections II and III are reached only if the plan does not incorporate by reference under Section I.
How are investment arrangements treated for RMD purposes?
Under Section I.b, each investment arrangement under the 403(b) plan is treated as an individual retirement account or annuity (IRA), with distributions made in accordance with Treas. Reg. 1.408-8, except as provided in 1.403(b)-6(e). The plan is not treated as a single account the way a 401(k) plan is.
What do I do with a No answer on Worksheet 9A?
A No indicates a problem exists, and it must be explained in the space provided in that section. Mark inapplicable items N/A rather than leaving them blank, and record a Plan Reference citation for every answered item.