Form 15417-I – Worksheet 16, Determination of 403(b) Status

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.

Form 15417-I narrows to a single, specific situation, and missing that is where reviews go sideways. It is Worksheet 16, the IRS examiner checklist that tests whether a 403(b)(9) Retirement Income Account plan meets qualification rules, and it applies only to church-related employers, a church or convention or association of churches under IRC §3121(w)(3). A plan that is not one of those is not the plan this worksheet measures.

Examiners work through seven sections with Yes, No, and N/A boxes, and any No has to be explained. Section I will not accept implied intent; the plan must be a defined contribution program and state outright that it is meant to be a retirement income account under §403(b)(9). If a group trust is used, only four asset categories may go in it. Sponsors never file this worksheet, but they have to be able to substantiate every answer an examiner records.

Key Takeaways

• Form 15417-I is Worksheet 16, the IRS examiner checklist for determining whether a 403(b)(9) Retirement Income Account plan meets qualification rules. It is an internal worksheet used during plan examinations, not a taxpayer-filed return.
• Form 15417-I applies only to 403(b)(9) Retirement Income Account plans sponsored by church-related organizations: a church, convention/association of churches (or church elementary/secondary school) under IRC §3121(w)(3)(A); a church retirement/welfare board under IRC §414(e)(3)(A); a QCCO under IRC §3121(w)(3)(B); or a self-employed minister/chaplain under IRC §414(e)(5)(A).
• Section I requires the plan to be a defined contribution program AND to specifically state that it is intended to constitute a retirement income account under IRC §403(b)(9); implicit intent is not sufficient.
• Each major section has an Explain any No answers prompt. A Yes generally indicates a favorable conclusion; a No indicates a problem that must be explained in the space provided on the worksheet.
• If a group trust is used, only four asset categories may be invested in it: retirement income account assets, custodial account assets, §401(a) qualified plan assets, and §408(a) or (b) individual retirement plan assets.

Why Firms Get Stuck On Something This Small

This rarely fails on effort, it fails on structure. Because Worksheet 16 is an internal examiner tool, teams forget that the work it tests lives in the plan document, not in a filing. Then an examination opens, a reviewer cannot find the language that supports a required Yes answer, a partner steps in, and the determination drags. The fix is not heroics, it is structure. Standard operating procedures, disciplined plan-document version control, prepared section references, and one accountable owner per plan will cut hours of back‑and‑forth and keep partners focused on strategy.

Common barriers you can eliminate fast:

• Scramble when an examination opens, solved with a plan-document substantiation file kept current year-round.
• Partner time trapped in review loops, solved with structured workpapers and a two‑step QC before partner review.
• Inconsistent quality across plan documents, solved with a template that maps each Section I–VII item on Worksheet 16 to the specific plan-document language an examiner can cite in the Plan Reference column.
• Workflow visibility gaps, solved with a simple tracker that shows owner, plan, section status, and open items at a glance.

If you are reading this on Accountably’s site, a quick note about our role. We are careful not to talk about ourselves where it does not help you. Where it matters, we share the delivery patterns that keep filings moving. If you file dozens or hundreds each season, we can help you codify the SOPs and review guardrails so these do not bounce. If not, use this checklist and keep shipping.

What Form 15417‑I Means In Plain English

The purpose

Form 15417-I is the IRS examiner worksheet titled Worksheet 16, Determination of 403(b) Status, used to evaluate whether a 403(b)(9) Retirement Income Account plan qualifies under the Internal Revenue Code. The worksheet has seven sections (I through VII), each with Yes, No, and N/A answer columns and a Plan Reference column for the examiner to cite the supporting plan-document language. It is an internal IRS examination tool, not a taxpayer filing – no signature, no deadline, no submission address.

What gets attached

• Plan-document language an examiner uses to record a Plan Reference for every Yes answer on Worksheet 16.
• Plan-document evidence that the retirement income account is a defined contribution program and is specifically intended to constitute a §403(b)(9) retirement income account.
• Supporting governing documents an examiner may ask for, for example, board resolutions adopting or amending the plan, trust agreements, and the documents that establish the sponsor's church-related-organization status.

Who completes it, and how

• Form 15417-I has no taxpayer submission process. IRS examiners complete the worksheet internally during a 403(b) plan determination examination.
• Plan sponsors do not file the form. The examiner enters Yes, No, or N/A on each Section I–VII item and records the supporting Plan Reference citation.
• Examiners must explain every No answer in the space provided in that section of the worksheet.

Accuracy note, IRS procedures can change. Always confirm against the current worksheet instructions and Treas. Reg. §1.403(b)-9. For this guide, details are aligned with procedures in effect as of October 31, 2025.

Eligibility And Jurisdiction, Who Can Use It And Where It Applies

Who qualifies

Section II of Worksheet 16 limits eligible sponsors of a 403(b)(9) retirement income account plan to church-related organizations as described in Treas. Reg. §1.403(b)-2(b)(6). Those categories are:

• A church, a convention or association of churches, or an elementary or secondary school of such (IRC §3121(w)(3)(A)).
• A church retirement/welfare board controlled by or associated with a church (IRC §414(e)(3)(A)).
• A qualified church-controlled organization, or QCCO (IRC §3121(w)(3)(B)).
• A self-employed minister or chaplain (IRC §414(e)(5)(A)), but solely with respect to a retirement income account established for that minister or chaplain.

The key is alignment. The adopting employer must fall within one of the four church-related-organization categories above, and the plan document must reflect that status. A self-employed minister or chaplain qualifies only with respect to a retirement income account established for that individual. Keep the sponsor's status and the plan-document language consistent.

Applicable authorities and limits

Section II item b requires plan eligibility to be limited to employees (as defined in Treas. Reg. §1.403(b)-2(b)(9)) of a church-related organization (including a Non-QCCO) and their beneficiaries, including self-employed ministers and chaplains. The plan must:

• Limit eligibility to employees (as defined in Treas. Reg. §1.403(b)-2(b)(9)) of a church-related organization, including a Non-QCCO, and their beneficiaries.
• Include self-employed ministers and chaplains within the eligible-employee group where the plan covers them.
• State the eligibility limitation in the plan-document language an examiner can cite in the Plan Reference column for Section II item b.

Limitations to keep in mind:

• Limit participation to employees of the four enumerated church-related categories and their beneficiaries, including self-employed ministers and chaplains.
• Include Non-QCCO employers on the employee-eligibility side, while recognizing that Non-QCCO sponsors trigger separate Section V nondiscrimination requirements that churches and QCCOs are exempt from.
• Attach all schedules and exhibits the form references. Scope that is vague or missing attachments delays processing.

Geographic scope

Form 15417-I is a federal IRS examiner worksheet used during 403(b)(9) plan determination examinations. It is not administered by any state revenue agency, it does not authorize representation, and it has no jurisdictional reach outside the IRS plan-examination process. Sponsors outside the four church-related-organization categories cannot establish a 403(b)(9) retirement income account.

Eligibility Trigger	Jurisdiction	Excluded Scope
Church or convention/association of churches	IRS 403(b)(9) plan determination examination	State revenue agency proceedings
Church retirement/welfare board	Federal §403(b)(9) qualification review	Taxpayer representation or authorization
Qualified church-controlled organization (QCCO)	Worksheet 16 Section I–VII determination	Sponsors outside the four church-related categories
Self-employed minister or chaplain	Retirement income account established for that individual	For-profit or non-church-related employers

Deadlines And Timelines, Why There Is No Submission Clock

Form 15417-I has no taxpayer filing deadline because it is not a taxpayer-filed return. The IRS examiner completes the worksheet during a plan determination examination. The relevant discipline for the plan sponsor is being able to substantiate every Yes answer with plan-document language when an examiner requests it; gaps surface during examination and drive plan-document corrections, not filings.

So the timeline you manage is not a submission clock, it is examination readiness. Keep the plan document current and mapped to Worksheet 16 before any examination opens.

Ways to stay ready:

• Keep one consolidated, version-controlled plan document on hand so you can answer an information request without rebuilding the file.
• When an examiner sends an information document request, note the response date stated on the request and calendar it the moment it arrives.
• Track open No-answer items with an owner and a target correction date, then keep proof of each plan amendment until the examination closes.

What the Worksheet Records, Field By Field

Form 15417-I has no taxpayer identifier fields. The worksheet contains Yes, No, and N/A answer columns and a Plan Reference column where the examiner cites the section of the plan document that supports each conclusion. The plan sponsor's job is to ensure the plan document itself contains language that supports every required Yes answer in Sections I through VII.

Helpful Plan Reference examples a sponsor can map to Worksheet 16 items:

• “Section I item b: plan states it is intended to constitute a retirement income account under §403(b)(9), Article 1.3.”
• “Section III item d: any loan or extension of credit from account assets to the employer is treated as a diversion, Article 4.2.”
• “Section VII item b: distributions are restricted in accordance with the rules applicable to annuity contracts, Article 7.1.”

Supporting Documents And Evidence, Packaging That Speeds Review

Think like a reviewer. They need to confirm identity, scope, and authority with minimal friction. Attach what the form and notice expect and line up names, dates, and periods across every exhibit. Keep sensitive data to the minimum required.

Required evidence types

• Plan-document language supporting each Yes answer across Sections I–VII: Applicability (defined contribution status and explicit §403(b)(9) intent), Employer Eligibility (church-related organization status), 403(b)(9) Requirements (separate accounting, performance tied to underlying assets, exclusive-benefit rule, loan-as-diversion clause), Funding Vehicles (commingling and group-trust rules), Nondiscrimination (Non-QCCO requirements), Limits (Worksheet 6A cross-reference), and Distributions (annuity-rule distributions and in-kind-use-as-distribution clause).
• Church-related-organization status proof, for example, the determination or governing documents that show the sponsor is a church, a church retirement/welfare board, a QCCO, or a self-employed minister or chaplain.
• Funding-vehicle evidence, the plan-document and trust language that supports the Section IV commingling and group-trust answers, including the four permissible group-trust asset categories.

Keep amendments dated and version-controlled, then keep section references consistent across the plan document and any board resolutions or trust agreements.

Document formatting tips that matter in real life

There is no taxpayer-submitted package for Form 15417-I. Plan sponsors instead maintain a clean copy of the plan document with section numbers an examiner can reference, keep amendments dated and version-controlled, and be able to point an examiner to the exact plan-document text that supports each Section I–VII item on Worksheet 16.

Action	Specification
Index	One page with exhibit letters, purpose, and page ranges
File naming	Document type plus ISO date, for example, PlanDoc_403b9_Amendment_2025‑03‑14.pdf
Scan settings	300 dpi, black‑and‑white or grayscale
Redaction	Remove SSNs and account numbers only, leave names, dates, and amounts
Corroboration	Receipts, time‑stamped emails, certified copies where required

Redact only protected data. If you remove amounts or dates, you make it harder to verify your claim and you increase the odds of a correction request.

How the Worksheet Moves Through an Examination

If speed and completeness matter, keep one clean, indexed copy of the plan document with section numbers an examiner can cite at a glance.

• Form 15417-I is not submitted by the taxpayer-sponsor. The IRS examiner completes the worksheet during the plan determination review using the plan document as the primary evidence base.
• The examiner records Yes, No, or N/A on each Section I–VII item and enters the supporting Plan Reference citation in the column provided.
• For every No answer, the examiner must explain in the space provided in that section; the sponsor responds by curing the underlying plan-document gap, not by filing the worksheet.

How the Examiner Records No Answers and What You Do Next

Form 15417-I has no submission-response cycle because there is no taxpayer submission. When the worksheet surfaces a No answer during examination, the examiner records the explanation in the space provided in that section and follows internal IRS examination procedures; the plan sponsor responds by addressing the underlying plan-document deficiency, not by filing or escalating a Form 15417-I record.

Why a No answer is not the end

A No answer flags a problem the examiner expects you to explain or cure. The technical principles tested on the worksheet may be superseded by future regulations or guidance, so plan sponsors should continue to monitor IRS and Treasury releases that touch §403(b)(9) and Treas. Reg. §1.403(b)-9 even after a successful examination. The practical move is to fix the plan-document language an item depends on, then point the examiner to the corrected article.

Curing Plan-Document Gaps Section by Section

Read the No answer, then read the plan article it tests

Each section of Worksheet 16 maps to specific plan-document language. When an item is answered No, work the cure in this order:

• Identify the Section I–VII item and the exact plan-document text it tests.
• Draft the amendment that adds the missing language, for example, explicit §403(b)(9) intent or the loan-as-diversion clause.
• Adopt the amendment through the plan's normal governance, dated and version-controlled.
• Update the Plan Reference so the examiner can verify the corrected article quickly.
• Keep the prior and amended versions in the substantiation file for the audit trail.

Keep the work objective and document-based. The goal is a plan an examiner can answer Yes against, not a back-and-forth.

Section V, the Non-QCCO branch

Section V item a is skipped entirely if 403(b) elective deferrals are the only contributions. Section V item b applies only when the employer is not a church or QCCO; in that case the plan must contain nondiscrimination language addressing universal availability for elective deferrals, minimum coverage, matching and after-tax contributions, IRC §401(a)(4) for non-matching employer contributions, and other limits, by reference to Worksheets 1A, 11A, 5B, and 6A.

Section IV, Commingling and Group-Trust Pitfalls

Section IV is where careful answers matter. N/A applies to the commingling question only when the plan does not provide for commingling in a common fund at all; if the plan permits commingling but does not limit it to amounts devoted exclusively to church purposes, the correct answer is No, and the examiner must explain. For a group trust, only four asset categories may be invested: retirement income account assets, custodial account assets, §401(a) qualified plan assets, and §408(a) or (b) individual retirement plan assets.

Plan provides for commingling, limited to church purposes	Answer Yes
Plan provides for commingling, no church-purpose limit	Answer No, and explain
Plan does not provide for commingling at all	Answer N/A
Group trust holds only the four permissible asset categories	Answer Yes
Plan does not use a group trust	Answer N/A

If an item would be answered No, treat it as a plan-document correction, not an appeal. Revise the language and re-map the Plan Reference.

Where Contribution Limits Are Actually Tested

Worksheet 16 does not contain the contribution-limit tests itself. Contribution limits for 403(b)(9) retirement income accounts, including the special rules for "denominational service," are tested through Worksheet 6A rather than Worksheet 16, so the limits review for a plan being examined is conducted there.

What an Examination Determination Looks Like, And the Three Outcomes You Will See

Here is the usual flow once a 403(b)(9) plan examination opens:

• The IRS examiner reviews the plan document against each item in Sections I through VII and marks Yes, No, or N/A in the appropriate column.
• For any No answer, the examiner explains the problem in the space provided and may issue an information document request for supporting plan language.
• If staff need verification, the sponsor may receive a call or a request to point to specific plan-document articles.
• When review finishes, the sponsor receives written notice of the determination and next steps.

Most outcomes fall into three buckets, a favorable determination, a short delay while the plan is corrected, or a finding that the plan must be amended to keep its §403(b)(9) status.

Typical plan-document fixes include adding explicit §403(b)(9) intent language under Section I item b, clarifying that the retirement income account is a defined contribution program under Section I item a, adding the loan-as-diversion clause required under Section III item d, narrowing eligibility language to employees of a church-related organization under Section II item b, and adding the annuity-contract distribution restrictions required under Section VII item b even when the underlying investments are mutual funds.

Tips For An Examination-Ready Plan-Document File

When an examination opens, your substantiation file should be unmistakably clear on the first read.

• Identify the plan-document section that supports each Yes answer on Worksheet 16, with article numbers and effective dates.
• Confirm the sponsor's church-related-organization status with the governing documents that prove it.
• Connect each Section I–VII item to the specific plan language an examiner can cite in the Plan Reference column.
• Keep dated amendments and prior versions so the audit trail is complete.
• Keep the index crisp and avoid filler.
• Have the supporting trust agreements and board resolutions filed alongside the plan document.

Common No-answer triggers and how to prevent them

• Section I item b language too generic, replace any generic "intended as a 403(b) plan" phrasing with explicit "intended to constitute a retirement income account under section 403(b)(9)."
• Sponsor status undocumented, keep the church-related-organization status documents with the plan document so Section II can be answered Yes.
• Section III item d loan-as-diversion clause missing, add the affirmative diversion language to the plan document.
• Section IV item a commingling language permissive without the church-purpose limit, revise the plan to limit commingling to amounts devoted exclusively to church purposes.
• Plan-document amendments scattered, consolidate into one indexed copy with section numbers an examiner can cite.

A simple template you can reuse

Index, one page at the front of the plan-document substantiation file:

• Section I, plan-document language stating explicit §403(b)(9) intent and defined contribution structure
• Section II, church-related-organization status documents and eligibility language, pp. 4–7
• Section III, separate accounting, performance, exclusive-benefit, and loan-as-diversion clauses, pp. 8–9
• Section IV, commingling and group-trust language, pp. 10–12
• Sections V–VII, nondiscrimination, Worksheet 6A limits cross-reference, and annuity-rule distribution restrictions, pp. 13–14

Plan Reference note, short and clear:

• For each Worksheet 16 item, record the plan-document article and section that supports a Yes answer.
• Keep the citations consistent with the consolidated plan document so an examiner can verify them quickly.

Version-control tip, keep amendments dated, paginate each page as 1 of N, 2 of N, and retain the prior versions for the audit trail.

Security And Work Integrity

Form 15417-I is an internal IRS examination tool, so there is no taxpayer transmission to secure. Plan sponsors instead protect the plan-document substantiation file: version-control amendments, keep board resolutions and trust agreements with the plan document, and maintain a single source of truth that an examiner can reference quickly during a determination review.

Operations patterns that keep you on schedule

• Intake SOPs, reviewers do not see work until intake is green.
• Internal checklists, accuracy and completeness must be checked before partner review.
• Turnaround SLAs, define what “examination-ready” means for a plan and who signs off on it.
• Visibility, dashboards for owner, plan, section-mapping status, and open items.
• Continuity, if someone is out, your SOP, index, and naming standards let another team member keep the substantiation file current.

A light touch from Accountably

We keep this brief and useful. If you administer 403(b)(9) plans at scale, Accountably can help build disciplined offshore delivery that fits your systems, not the other way around, with SOP‑driven execution, structured workpapers, layered review, and clear SLAs. That way, your plan-document substantiation files stay examination-ready without dragging partners back into production.

Putting It All Together, A Simple Game Plan

• Gather facts, pull the current plan document, confirm the sponsor's church-related-organization status, and collect the supporting governing documents.
• Prepare the plan-document substantiation pack: confirm explicit §403(b)(9) intent and defined contribution status, confirm the employer fits one of the four church-related-organization categories, confirm separate accounting and the loan-as-diversion clause, and confirm the annuity-contract distribution restrictions.
• Map each Worksheet 16 Section I–VII item to a plan-document Plan Reference so an examiner can verify every Yes answer quickly.
• If an item would be answered No, plan the plan-document correction, assign an owner, and set a target date.
• Keep amendments dated and version-controlled so the substantiation file stays examination-ready.

You do not need heroics, you need discipline. Clear scope, clean files, one owner, and a single source of truth. That is how a plan stays examination-ready.

Short Disclaimer

This article is general information about IRS Form 15417-I, Worksheet 16, used by IRS examiners during 403(b)(9) plan determination reviews. The technical principles in the worksheet may be changed by future regulations or guidance. Always confirm current rules in the worksheet (Form 15417-I, Rev. 4-2023, Catalog No. 94037R), IRC §403(b)(9), and Treas. Reg. §1.403(b)-9, and consult a qualified professional for advice on your facts.

Common Mistakes We See Every Season

The same handful of errors show up across 403(b)(9) plan-document reviews, and each one creates rework or delay. Here are the ones we see most often and the SOP fix that prevents them.

Reusable Checklists

These are copy-paste ready for firm SOPs and plan administrators running a single plan. Each item is one row a preparer can check off to keep a 403(b)(9) plan examination-ready.

Keep 15417-I Season From Stalling

403(b)(9) plan determinations move quickly when the plan-document substantiation file is already mapped to Worksheet 16 sections. Sections I and II turn on plan-document language and sponsor status; Sections III and IV turn on specific clauses an examiner expects to find verbatim; and Sections V, VI, and VII route through nondiscrimination, Worksheet 6A limits, and annuity-rule distribution restrictions.

The fix is not more hours. It is a substantiation file you can rebuild the same way every time, a single owner per plan, and a visible status everyone working the file can see at a glance.

• Build a standard plan-document index that maps each Section I–VII item on Worksheet 16 to the exact plan-document section, page, and effective date the examiner can cite as the Plan Reference.
• Assign one preparer per plan and one reviewer who signs off on the section mapping, the sponsor-status proof, and the open-item list before the file is called examination-ready.
• Calendar any information-document-request response date the moment a request arrives, and add a buffer reminder seven days ahead.
• Standardize the naming convention on every plan-document amendment, so an examiner can match an article to a Worksheet 16 item without searching.
• Log every amendment with article number, adoption date, and effective date, so the substantiation file stays examination-ready without rebuilding it from scratch.

At Accountably, our tax outsourcing services wrap this discipline into a documented workflow, so partners see clean files, clients see consistent delivery, and plan-level SLAs hold even when examination volume spikes.

FAQs

Who completes Form 15417-I?

IRS examiners complete Form 15417-I during 403(b) plan determination examinations. It is an internal IRS worksheet, not a taxpayer-filed return. Plan sponsors do not sign or file it, but they must be able to point to plan-document language that supports every Yes answer when an examiner asks.

Can a 403(b)(9) plan be structured as a defined benefit plan?

No. Section I item a of Worksheet 16 requires the retirement income account to be a defined contribution program. A defined benefit structure disqualifies the plan from 403(b)(9) status.

Can any 501(c)(3) tax-exempt entity sponsor a 403(b)(9) plan?

No. Section II limits eligible sponsors to church-related organizations as described in Treas. Reg. §1.403(b)-2(b)(6): a church or convention/association of churches (or church school) under IRC §3121(w)(3)(A); a church retirement or welfare board under IRC §414(e)(3)(A); a qualified church-controlled organization (QCCO) under IRC §3121(w)(3)(B); or a self-employed minister or chaplain under IRC §414(e)(5)(A), but only for that individual's own account.

When is N/A the correct answer on the Section IV commingling question?

N/A applies only when the plan does not provide for commingling in a common fund at all. If the plan permits commingling but does not limit it to amounts devoted exclusively to church purposes, the correct answer is No, not N/A, and the examiner must explain in the space provided.

Does Section V nondiscrimination apply to every 403(b)(9) plan?

No. Section V item a is skipped entirely if 403(b) elective deferrals are the only contributions to the plan. Section V item b applies only to employers that are not a church or QCCO; Non-QCCO sponsors must include nondiscrimination language addressing universal availability for elective deferrals, minimum coverage, matching and after-tax contributions, IRC §401(a)(4) for non-matching employer contributions, and other limits, as cross-referenced to Worksheets 1A, 11A, 5B, and 6A.