Form 15417-F – 403(b) Worksheet 11A: ACP Test for Matching Contributions

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Most of the time when a 403(b) review on Worksheet 11A bogs down, someone has started filling in the matching-contribution math before answering whether the worksheet applies at all. Form 15417-F covers the Section 401(m) nondiscrimination rules, and a plan that offers only elective deferrals never reaches them. Governmental plans under Section 414(d) and church or QCCO plans under Section 3121(w)(3) stop at Section I.

Settle applicability first, then commit to a single compliance path before any computation: the 401(m)(11) safe harbor, the 401(m)(12) QACA safe harbor, or the regular ACP test. This is Catalog No. 94034K (Rev. 4-2023), an internal reviewer worksheet, not a return anyone files.

Key Takeaways

• Form 15417-F is Worksheet 11A in the IRS 403(b) plan determination series (Catalog No. 94034K, Rev. 4-2023) – a six-page reviewer worksheet for the Section 401(m) nondiscrimination requirements covering matching and employee after-tax contributions.
• Who uses it: IRS reviewers and the plan sponsors, third-party administrators, and advisors preparing 403(b) plans for determination, restatement, or internal compliance review. It is an internal worksheet, not a return filed by taxpayers.
• When it applies: Only when the plan provides employer matching, voluntary or mandatory employee after-tax contributions, or allocates forfeitures based on elective contributions. A deferrals-only plan does not trigger it.
• Exempt plans: Governmental plans under Section 414(d) and church or QCCO plans under Section 3121(w)(3) are not subject to Section 401(m); the worksheet stops at Section I for them.
• Three compliance paths: The plan can satisfy Section 401(m) through the 401(m)(11) safe harbor (Section IV), the 401(m)(12) QACA safe harbor (Section V), or the regular ACP test (Sections VI and VII).
• SOP tip: Settle applicability in Section I first, then commit to one compliance path before working the math. Cross-check coverage on Form 15417-C, Worksheet 5B, referenced from Section II.

What Form 15417-F Is and When to Use It

Form 15417-F is Worksheet 11A in the IRS 403(b) plan determination series, carrying Catalog No. 94034K and a revision date of April 2023 (4-2023). It is an internal reviewer worksheet that walks through the Section 401(m) nondiscrimination requirements for matching contributions and employee after-tax contributions under a 403(b) plan. It is not a return a taxpayer files; it is the tool a reviewer uses to confirm a plan meets the rules.

Every item on the worksheet is answered Yes, No, or N/A against a plan reference. A Yes generally signals a favorable conclusion, while a No flags a problem that must be explained in the space provided. The worksheet runs six pages across nine major sections, Sections I through IX.

Worksheet 11A is not needed for every 403(b) plan. Section I narrows the field: the worksheet applies only when the plan provides employer matching contributions, voluntary or mandatory employee after-tax contributions, or allocates forfeitures based on a participant’s elective contributions. If none of those features is present, the analysis stops there.

Plans Exempt from Section 401(m)

Section I also screens out plans that are not subject to Section 401(m) at all. A governmental plan within the meaning of Section 414(d), and a plan maintained by a church under Section 3121(w)(3)(A) or a qualified church-controlled organization (QCCO) under Section 3121(w)(3)(B), are exempt. For these plans the reviewer stops at Section I and does not complete the remainder of the worksheet.

Three Ways to Satisfy Section 401(m)

Section III directs the reviewer to the chosen compliance path. A 403(b) plan with matching or after-tax contributions can satisfy Section 401(m) in one of three ways: the 401(m)(11) safe harbor (reviewed in Section IV), the 401(m)(12) QACA safe harbor (reviewed in Section V), or the regular actual contribution percentage (ACP) test under Section 401(m)(2)(A) (reviewed in Sections VI and VII). Keep in mind that the ADP test does not apply to 403(b) plans, though the ACP safe harbor borrows some ADP safe harbor mechanics.

How the Worksheet Is Organized

Worksheet 11A is built to be worked top to bottom. Each section either gates the analysis or maps to a specific compliance path, so a reviewer never runs every section on every plan.

Section	What It Covers	Practitioner Tip
I. Applicability	Whether the worksheet applies and whether the plan is exempt (governmental or church/QCCO)	Settle this first; a wrong answer here wastes the rest of the review
II. Coverage	Coverage for matching and employee contributions	Cross-reference Form 15417-C, Worksheet 5B, rather than re-deriving coverage
III. Matching Contributions	How the plan specifies it will meet Section 401(m): safe harbor, QACA, or ACP test	Commit to one path before working any later section
IV & V. Safe Harbors	Non-QACA 401(m)(11) safe harbor (IV) and QACA 401(m)(12) safe harbor (V)	Tie the match formula in the workpaper to the correct section
VI – VIII. ACP Test & QNECs	The ACP test, corrections to failures, and QNECs treated as matching contributions	Use the correct leveling methods and confirm QNEC vesting and distribution rules
IX. HCE / Compensation	Definitions of highly compensated employee and compensation	Confirm the Section 414(q) definition and the Section 414 aggregation rules

Every No answer must be explained in the space provided. N/A is appropriate only when the employer has not requested a determination on that item and is not otherwise required to address it. The IRS also notes that the technical principles in the worksheet may be changed by future regulations or guidelines.

Safe Harbor Matching Paths

Two of the three compliance paths are safe harbors. They share a structure but use different formulas, vesting rules, and section references.

Non-QACA Safe Harbor (Section IV)

The non-QACA basic matching formula is 100% of the first 3% of compensation deferred plus 50% of the next 2%, which produces a maximum 4% employer match when the employee defers 5%. An enhanced formula qualifies only if it provides at least as much matching as the basic formula at every deferral level. Traditional non-QACA safe harbor contributions must be 100% vested immediately. Matching is not made on after-tax or elective contributions exceeding 6% of compensation, and any discretionary match is capped at 4% of compensation; exceeding that cap fails the safe harbor and the regular ACP test applies.

QACA Safe Harbor (Section V)

The QACA basic matching formula is 100% of the first 1% of compensation deferred plus 50% of the next 5%, for a maximum 3.5% match at a 6% deferral. QACA safe harbor contributions to NHCEs may vest over no more than 2 years of service. The same 6% matching cap and 4% discretionary-match cap apply. The QACA path also incorporates the QACA ADP safe harbor notice and contribution requirements when used to satisfy the ACP test safe harbor.

Conditions That Apply to Both

Safe harbor matching and nonelective contributions must be made for every eligible NHCE with no hours-of-service or last-day-of-year condition. Safe harbor provisions must be adopted before the plan year begins and stay in effect for the entire 12-month plan year, with short-plan-year rules under Treasury Regulation 1.401(m)-3(f). For hardship distributions made on or after January 1, 2020, the plan must allow elective contributions to continue.

The ACP Test and Corrections

When the plan does not rely on a safe harbor, Section VI runs the actual contribution percentage (ACP) test and Section VII covers corrections. Salary reduction contributions under a 403(b) plan cannot be taken into account for the ACP test; only matching, after-tax employee contributions, and qualifying QNECs are included.

Testing Method

The plan must specify whether it uses the prior-year or current-year testing method. If it uses the prior-year method, it must state whether the first-year ACP for eligible NHCEs is treated as 3% or as the actual first-year ACP. For the HCE side, all plans under which an HCE is eligible to make employee contributions or receive matching contributions are aggregated when computing the HCE’s contribution ratio.

Correcting a Failure

Excess aggregate contributions must be distributed or forfeited after the end of the plan year and no later than 12 months following the end of that plan year. A separate, earlier deadline applies to avoid the employer excise tax under Section 4979, so many plans correct sooner; the 12-month window is the outer limit for correcting the failure itself. The amount to distribute is determined with the ratio leveling method, while the distribution or forfeiture allocation uses the dollar leveling method.

Match Forfeiture

If the plan distributes matched employee contributions as excess aggregate contributions, it must also forfeit the corresponding matching contributions. Under the current-year method, the plan should also provide a correction mechanism, either QNECs to satisfy the test or a distribution and forfeiture mechanism for excess aggregate contributions.

QNECs, HCEs, and Compensation

Section VIII addresses qualified nonelective contributions (QNECs) when the plan provides that they are treated as matching contributions for the ACP test, and Section IX covers the definitions of highly compensated employee and compensation.

QNECs treated as matching contributions must be immediately vested without regard to a participant’s age or service, and may be distributed only under the distribution rules for elective contributions under a cash or deferred arrangement (CODA), other than the hardship rules. In other words, QNECs are not available for hardship distribution under the safe harbor.

For Section IX, the plan must define highly compensated employee in accordance with Section 414(q), including the determination year, lookback year, compensation, and, if applicable, the top-paid group, and must apply the Section 414 aggregation rules. The plan must also define the compensation and the measurement period used for the ACP test, and use an allowable definition of compensation when checking safe harbor contribution amounts and limits.

The 15417 Series and Related Worksheets

The 15417 series is a set of internal IRS worksheets used in 403(b) plan determinations, with each letter covering a different aspect of plan qualification. Worksheet 11A (Form 15417-F) handles the Section 401(m) nondiscrimination requirements for matching and employee after-tax contributions. The most directly related worksheet for a Worksheet 11A review is the coverage worksheet referenced from Section II.

Worksheet	Focus	Relationship to 15417-F
Form 15417-F (Worksheet 11A)	Section 401(m) nondiscrimination for matching and after-tax contributions	This worksheet
Form 15417-C (Worksheet 5B)	403(b) plan coverage requirements	Referenced from Section II for coverage of matching and employee contributions

Quick rule you can copy into your SOP: pull the completed Worksheet 5B (Form 15417-C) into the file before starting Section II of Worksheet 11A, so coverage is established once rather than re-derived. When a plan offers more than one type of contribution, work each compliance path against the section that governs it instead of mixing rules across sections.

Common Mistakes That Slow Things Down

From my side of the desk, the same handful of slips turn a clean Worksheet 11A review into rework. Here are the ones we catch most often, with the fix we paste into the SOP.

Practical Checklists You Can Reuse

These are copy-paste ready for a firm SOP or plan-review workpaper. Each maps to a section of Form 15417-F so a reviewer can work top to bottom.

Keep 15417-F Season From Stalling

403(b) nondiscrimination work tends to land in waves, around determination-letter submissions and plan restatement cycles, and Worksheet 11A is rarely a quick read. It runs nine sections (Sections I through IX) and forces a single choice among three compliance paths, so a thin set of workpapers turns the review into a back-and-forth that eats senior time, per the IRS 403(b) plan worksheets.

The fix is not more reviewers. It is structure: a defined applicability gate, one documented compliance path, and the supporting math captured before anyone signs off.

• Settle applicability in Section I first, then commit to one of the three Section 401(m) paths so the rest of the worksheet has a clear target.
• Capture the basic match math once: 100% of the first 3% plus 50% of the next 2% for non-QACA (maximum 4%), versus 100% of the first 1% plus 50% of the next 5% for QACA (maximum 3.5%).
• Tie coverage back to Form 15417-C, Worksheet 5B, from Section II rather than re-deriving it.
• Pre-stage the ACP correction window so excess aggregate contributions are distributed or forfeited within 12 months of plan year end.

That discipline is exactly what we build into delivery. Structured workpapers, a single documented review path, and turnaround SLAs keep plan-compliance work moving without burning senior hours, which is the core of our tax execution services.

FAQs

What is Form 15417-F used for?

Form 15417-F is Worksheet 11A in the IRS 403(b) plan determination series (Catalog No. 94034K, Rev. 4-2023). It is an internal reviewer worksheet that walks through the Section 401(m) nondiscrimination requirements for matching contributions and employee after-tax contributions in a 403(b) plan. Each item is answered Yes, No, or N/A across nine sections, Sections I through IX.

Which 403(b) plans does Worksheet 11A apply to?

Worksheet 11A applies only when a 403(b) plan provides employer matching contributions, voluntary or mandatory employee after-tax contributions, or allocates forfeitures based on a participant’s elective contributions. A plan with elective deferrals only does not trigger it. Governmental plans under Section 414(d) and church or QCCO plans under Section 3121(w)(3) are not subject to Section 401(m), so the worksheet stops at Section I for them.

What are the three ways a 403(b) plan can satisfy Section 401(m)?

A 403(b) plan with matching or after-tax contributions can satisfy Section 401(m) through the 401(m)(11) safe harbor (Section IV), the 401(m)(12) QACA safe harbor (Section V), or the regular ACP test (Sections VI and VII). Section III of the worksheet directs the reviewer to the chosen path.

How do the non-QACA and QACA safe harbor basic match formulas differ?

The non-QACA basic match is 100% of the first 3% of compensation deferred plus 50% of the next 2%, for a maximum 4% match, and must be 100% vested immediately. The QACA basic match is 100% of the first 1% plus 50% of the next 5%, for a maximum 3.5% match, and may vest over no more than 2 years of service. Under both safe harbors, matching is not made on deferrals above 6% of compensation, and any discretionary match is capped at 4% of compensation.

What is the deadline to correct an ACP test failure?

Excess aggregate contributions must be distributed or forfeited after the end of the plan year and no later than 12 months following the end of that plan year. A separate, earlier deadline applies to avoid the employer excise tax under Section 4979, so practitioners often correct sooner; the 12-month window is the outer limit for correcting the failure itself.