Editorial Standards
How we research, review, and update this guide
Every Accountably guide is researched against primary IRS sources, reviewed by a U.S. CPA, and refreshed as guidance evolves. Read our Editorial Guidelines to see how we source, fact-check, and update our content.
When a 403(b) plan goes through a determination or examination, this is the worksheet the IRS reviewer fills in to decide whether the plan's distribution provisions actually satisfy 403(b) status. It is not a participant filing and not a sponsor filing. Form 15417-H is Worksheet 15, revised April 2023, catalog number 94036G, completed by IRS personnel.
The worksheet runs eight sections covering elective deferrals, employer contributions, custodial account contributions, after-tax contributions, rollovers, and loans. Two dollar thresholds carry weight: $500 is the minimum eligible rollover distribution a plan must let distributees elect for direct transfer, and $1,000 is the line above which mandatory distributions default to an automatic rollover. Each row is marked Yes, No, or N/A, and one quiet trap is writing age 59 where the rule is 59½.
Key Takeaways
- Form 15417-H is Worksheet 15 – Determination of 403(b) Status – an IRS internal reviewer worksheet (revised April 2023, catalog number 94036G) used to evaluate whether a 403(b) plan's distribution provisions satisfy 403(b) status requirements.
- Who uses it: IRS reviewers evaluating 403(b) plans during a determination or examination. The worksheet is completed by IRS personnel; it is not signed or filed by plan participants or plan sponsors.
- Structure: The worksheet has eight sections (I-VIII) covering elective deferrals, employer contributions in annuity contracts or retirement income accounts, 403(b)(7) custodial account employer contributions, after-tax employee contributions, rollover contributions, loans, rollovers and cash outs, and miscellaneous items. The form is five pages long.
- Answer format: Each row is marked Yes, No, or N/A. A Yes generally indicates a favorable conclusion; a No indicates a problem; N/A applies when an event simply is not included. Using age 59 instead of 59½ is explicitly flagged as improperly included (No, not N/A).
- Key dollar thresholds: $500 is the minimum eligible rollover distribution the plan must allow distributees to elect for direct transfer; $1,000 is the threshold above which mandatory distributions must default to an automatic IRA rollover when the participant does not elect.
- Cross-reference: Excess employer contributions are routed to Worksheet 6A, Plan Limitations on Contributions and Benefits. The §72(m)(7) disability definition is not the exclusive standard for Section II employer-contribution distributions.
What Form 15417-H Is and When to Use It
Form 15417-H, “403(b) Plan Distributions,” is Worksheet 15 – Determination of 403(b) Status in the IRS reviewer worksheet set (revised April 2023, catalog number 94036G). The worksheet is completed internally by IRS reviewers to determine whether a 403(b) plan's distribution provisions satisfy the requirements for 403(b) status under the Internal Revenue Code.
A 403(b) plan is a tax-sheltered annuity arrangement available to public school employees and employees of 501(c)(3) organizations under IRC §403(b). Worksheet 15 walks the reviewer through each category of contributions held inside a 403(b) plan – elective deferrals, employer contributions in annuity contracts or retirement income accounts, 403(b)(7) custodial account employer contributions, after-tax employee contributions, rollover contributions – and confirms that the plan's distribution provisions satisfy the Code's restrictions for each category.
The worksheet is graded with three answer choices per row: Yes, No, or N/A. A Yes generally indicates a favorable conclusion; a No indicates a problem; N/A is used when an event is simply not included. Reviewers must complete every item, explain any No answer in the space provided, and recognize that not all listed events are required – a missing event is marked N/A, while an improperly included event (for example, using age 59 instead of 59½) is marked No.
How Worksheet 15 Fits the 403(b) Reviewer Set
Form 15417-H is Worksheet 15 in the IRS reviewer worksheet series. It is not a participant or sponsor filing – it is the worksheet IRS personnel use to confirm that a plan's distribution provisions satisfy 403(b) requirements during a determination or examination. The technical principles in the worksheet may be changed by future regulations or guidelines.
When Form 15417-H Is Used
The worksheet is used internally by IRS reviewers evaluating a 403(b) plan. All items must be completed. A Yes answer generally indicates a favorable conclusion is warranted, while a No answer indicates a problem exists. Reviewers use the space on the worksheet to explain any No answer, and they distinguish a missing event (mark N/A) from an improperly included event (mark No) – for example, a plan that uses age 59 instead of 59½ is marked No, not N/A.
How to Complete Form 15417-H
The worksheet is completed by IRS reviewers. Each row has a Plan Reference column followed by Yes, No, and N/A boxes. Reviewers walk through the plan document, record the plan citation, mark the answer, and use the space on the worksheet to explain any No.
| Column | What to Provide | Reviewer Note |
|---|---|---|
| Plan Reference | Section, article, or page of the plan document where the provision appears | Record the citation so the conclusion can be retraced from the plan document |
| Yes | Mark when the plan provision satisfies the worksheet item | Generally indicates a favorable conclusion is warranted for that item |
| No | Mark when an event is included in the plan but framed improperly | Indicates a problem exists; the worksheet space must be used to explain the No |
| N/A | Mark when the event is simply not included in the plan | Not every listed event needs to be in the plan; missing events are N/A, not No |
| Section grouping (I–VIII) | Eight sections covering elective deferrals, annuity employer contributions, 403(b)(7) custodial employer contributions, after-tax employee contributions, rollover contributions, loans, rollovers and cash outs, and miscellaneous | Complete every item in every section that is in scope for the plan under review |
Reading the Yes / No / N/A Answers
A Yes answer generally indicates a favorable conclusion is warranted; a No indicates a problem exists. N/A is used when an event is simply not included; No is used when an event is included but framed improperly – for example, a plan that uses age 59 instead of 59½ for distributions of elective deferrals or 403(b)(7) custodial-account employer contributions is marked No, not N/A. The technical principles in the worksheet may be changed by future regulations or guidelines.
Section I – Permissible Distribution Events for Elective Deferrals
Section I confirms that 403(b) elective deferrals (including designated Roth contributions) cannot be distributed earlier than a permissible event.
Separate Elective Deferral Account
The first question in Section I asks whether the plan maintains elective deferrals in a separate account. If yes, the only distribution restrictions for that account are the ones in Section I. If there is no separate elective deferral account, distributions from the participant's account may not be made earlier than the later of any date under Section I and any date applicable under Sections II and III.
General-Rule Distribution Events (Five)
Under the general rule, 403(b) elective deferrals may not be distributed earlier than (i) death, (ii) disability, (iii) severance from employment, (iv) attainment of age 59½, or (v) participant hardship. A plan that uses age 59 instead of 59½ is marked No (not N/A), since the event is included but improperly framed.
Special-Situation Distribution Events (Nine)
The section also lists nine special-situation events: (i) termination of the plan; (ii) pre-1989 elective deferrals (not earnings on them); (iii) QDRO; (iv) IRS levy; (v) qualified reservist distribution; (vi) qualified birth or adoption distribution; (vii) coronavirus-related distribution; (viii) disaster-related distributions; (ix) lifetime income investment distribution. The pre-1989 carve-out covers only the deferral principal – earnings on pre-1989 deferrals are not eligible under this exception.
Hardship Distribution Standards
If hardship distributions of elective deferrals are permitted, the plan document itself must set forth all the Code requirements for hardship distributions. Specific operational terms may be incorporated by reference to the investment arrangement, but the Code requirements have to appear in the plan. Hardship distributions must either follow the safe-harbor standard of Treas. Reg. §1.401(k)-1(d)(3) and §1.403(b)-6(d)(2) or use an alternative standard that is nondiscriminatory and based on objective criteria.
Sections II and III – Employer Contribution Distributions
Sections II and III cover permissible distributions of employer contributions, split by where the contributions are held.
Section II addresses contributions held in annuity contracts or retirement income accounts – nonelective employer contributions, matching contributions, contributions made by an employee's one-time irrevocable election at initial eligibility, and employee contributions made as a condition of employment. Under the general rule, those contributions may not be distributed earlier than severance from employment or the prior occurrence of some event (for example, a fixed number of years, attainment of a stated age, or disability). Disability under Section II is not limited to the §72(m)(7) definition.
Section III addresses employer contributions in 403(b)(7) custodial accounts. The general rule limits distributions to (i) death, (ii) disability, (iii) severance from employment, or (iv) attainment of age 59½. Both Section II and Section III recognize eight special-situation events – termination of the plan, excess employer contributions (cross-referenced to Worksheet 6A, Plan Limitations on Contributions and Benefits), QDRO, IRS levy, qualified birth or adoption distribution, coronavirus-related distribution, federally declared disaster, and lifetime income investment distribution.
Sections IV, V, and VI – After-Tax, Rollover, and Loan Provisions
Sections IV, V, and VI cover three contribution and loan categories with their own distribution rules.
Section IV – After-Tax Employee Contributions
If the plan permits after-tax employee contributions, the plan may provide that, to the extent permitted by the terms governing the applicable investment arrangement, after-tax employee contributions may be distributed at any time. The restrictive triggers that apply to elective deferrals do not automatically apply here.
Section V – Rollover Contributions
If the plan has a separate account attributable to rollover contributions, the participant may elect at any time to receive a distribution of all or any portion of the amount held in the rollover account, to the extent permitted by the applicable investment arrangement. Rollover accounts are not locked up by the age 59½ or severance restrictions that apply to elective deferrals.
Section VI – Loans
A plan is not required to permit participant loans; Section VI is marked N/A if it does not. If the plan does permit loans, the worksheet asks for three required terms: a fixed repayment schedule, a reasonable rate of interest, and repayment safeguards to which a prudent lender would adhere. The plan must also provide that loans are subject to IRC §72(p), which limits the amount and the repayment period. If the plan allocates responsibility for performing administrative functions of the loan, the allocation must identify the party responsible for compliance with the Internal Revenue Code requirements.
Section VII – Rollovers, Cash Outs, and the $500 / $1,000 Thresholds
Section VII covers the rollover and cash-out provisions. Two distinct dollar thresholds appear here and are commonly confused.
| Provision | Threshold | Trigger |
|---|---|---|
| Distributee-elected direct rollover | $500 minimum | The plan must allow distributees to elect to have eligible rollover distributions that are at least $500 transferred directly to an eligible retirement plan. |
| Mandatory distribution – automatic IRA rollover | Greater than $1,000 | If the plan provides for mandatory distributions, then for a mandatory distribution greater than $1,000 where the participant does not elect a direct rollover or to receive the distribution directly, the plan administrator must pay it as a direct rollover to an IRA the administrator designates. |
| Required plan definitions | Three terms | The plan must define an eligible rollover distribution, an eligible retirement plan, and a distributee. |
| §402(f) written explanation | Reasonable period before distribution | The payor must provide a written explanation that satisfies the requirements of §402(f) within a reasonable period before making an eligible rollover distribution. |
| Nonspouse beneficiary direct rollover | Inherited IRA only | A nonspouse designated beneficiary may directly roll over the distribution only to an IRA described in §408(a) or §408(b) that is established for the beneficiary and treated as an inherited IRA under §408(d)(3)(C). |
The $500 and $1,000 thresholds are not interchangeable. The $500 figure is the minimum the plan must allow for a distributee-elected direct rollover. The $1,000 figure is the threshold above which a mandatory distribution defaults to an automatic IRA rollover when the participant fails to elect. Mixing them up is the most common misread of Section VII.
Common Mistakes That Slow Things Down
Most issues we see when reviewing Worksheet 15 conclusions are framing errors – the plan provision is there but is built around the wrong threshold, the wrong definition, or the wrong cross-reference. The five below are the most common.
Practical Checklists You Can Reuse
The checklists below mirror the Worksheet 15 review flow. Adapt the language to match how your team labels engagements.
Pre-review setup checklist
- Confirm the plan under review is a 403(b) plan (public school employer or 501(c)(3) organization).
- Pull the current Form 15417-H (Rev. 4-2023, catalog 94036G) and confirm it is the 4-2023 revision.
- Locate the plan document, all amendments, and any incorporated investment arrangement terms.
- Identify which sections (I–VIII) are in scope based on contribution types the plan holds.
- Note any cross-reference to Worksheet 6A for excess employer contributions.
- Populate the Plan Reference column with citations from the plan document before marking Yes / No / N/A.
Distribution events checklist (Sections I–III)
- Section I general rule: confirm death, disability, severance, age 59½, and participant hardship are properly framed.
- Flag any use of age 59 instead of 59½ as No (not N/A).
- Section I special situations: confirm the nine events including the pre-1989 elective deferrals (not earnings thereon) carve-out.
- Section II: confirm severance and prior-event triggers for annuity-contract employer contributions; do not force the §72(m)(7) disability definition.
- Section III: confirm the four 403(b)(7) custodial general-rule events (death, disability, severance, age 59½) and the eight special-situation events.
- Confirm hardship distributions either follow the safe-harbor standard of Treas. Reg. §1.401(k)-1(d)(3) and §1.403(b)-6(d)(2) or an alternative nondiscriminatory, objective-criteria standard.
Loans, rollovers, and cash-outs checklist (Sections VI–VII)
- Section VI: if the plan permits loans, confirm a fixed repayment schedule, a reasonable rate of interest, and prudent-lender repayment safeguards.
- Confirm the plan provides that loans are subject to IRC §72(p) (amount and repayment-period limits).
- Confirm loan-administration responsibility is allocated to a named party for IRC compliance.
- Section VII: confirm the $500 minimum for distributee-elected direct rollovers.
- Confirm the $1,000 mandatory-distribution automatic IRA rollover provision if the plan provides for mandatory distributions.
- Confirm the §402(f) written explanation will be provided within a reasonable period before the distribution.
- Confirm nonspouse beneficiary direct rollovers are limited to inherited IRAs under §408(a)/(b) and §408(d)(3)(C).
- Confirm the plan defines eligible rollover distribution, eligible retirement plan, and distributee.
Keep 403(b) Plan Reviews From Stalling
Worksheet 15 sits inside a broader 403(b) plan determination or examination. Reviews stall when the plan document leaves a Section I age threshold, a Section VI loan term, or a Section VII rollover definition open to interpretation – the reviewer writes a No, the sponsor files a corrective amendment, and the cycle repeats.
The fix is to pre-screen the plan provisions Worksheet 15 actually tests before the IRS opens its review, not after.
- Read each plan distribution provision against the exact Worksheet 15 question. Where the plan paraphrases, the worksheet tests the literal wording.
- Pin every age threshold to 59½ (not 59) wherever Section I or Section III applies.
- Make sure the hardship provisions sit in the plan document itself, not only in the investment arrangement.
- Set the Section VII elective direct-rollover floor at $500, the mandatory automatic IRA rollover trigger above $1,000, and the §402(f) written explanation timing as “within a reasonable period before” the distribution.
- Limit nonspouse beneficiary direct rollovers to inherited IRAs under §408(a)/(b) and §408(d)(3)(C).
- Tie loan provisions to IRC §72(p) by name, and allocate loan administration to a named party for IRC compliance.
This is the kind of work where the bottleneck is bandwidth and follow-through, not knowledge. Our taxation practice reviews 403(b) plan distribution provisions against Worksheet 15 before the IRS does, so reviewers do not find easy defects on a quiet read.
FAQs
What is Form 15417-H used for?
Form 15417-H is the IRS reviewer's Worksheet 15 – Determination of 403(b) Status (revised April 2023, catalog number 94036G). It is an internal IRS worksheet used during examination or determination of a 403(b) plan to evaluate whether the plan's distribution provisions satisfy 403(b) requirements. It is not filed by taxpayers or plan sponsors.
What are the eight sections of Form 15417-H?
The worksheet is divided into eight sections (I through VIII): I. Permissible distribution events for elective deferrals; II. Employer contributions in annuity contracts or retirement income accounts; III. Employer contributions from 403(b)(7) custodial accounts; IV. After-tax employee contributions; V. Rollover contributions; VI. Loans; VII. Rollovers and Cash Outs; and VIII. Miscellaneous.
What is the minimum distribution age referenced on Form 15417-H?
Age 59½. The worksheet explicitly notes that using age 59 (without the half) is improperly included for distributions of elective deferrals and 403(b)(7) custodial account employer contributions; a plan that uses age 59 is marked No (not N/A), since it is not properly included.
What are the $500 and $1,000 thresholds on Form 15417-H?
$500 is the minimum amount of an eligible rollover distribution that the plan must allow distributees to elect to have directly transferred to an eligible retirement plan. $1,000 is the threshold above which a mandatory distribution must default to a direct rollover to an IRA designated by the plan administrator when the participant does not elect a direct rollover or to receive the distribution directly. The two thresholds are distinct; confusing them is a common worksheet misread.
What is the current revision of Form 15417-H?
April 2023 (4-2023), catalog number 94036G, five pages, published by the Department of the Treasury – Internal Revenue Service. The 4-2023 revision is the current version applicable to 2025 tax year 403(b) plan reviews.