- When will this new reporting method be implemented?
Our goal is to go live with the new reporting system on July 1, 2020.
- Why is TRS making this change?
PA 100-0769 requires TRS to offer an optional Defined Contribution plan for all members, regardless of Tier. Defined contribution plans inherently come with certain reporting requirements which require changing from annual reporting to pay-period reporting.
- What is required of employers during implementation?
TRS expects districts that do in-house programming, as well as districts who use other vendors, to start development based on the requirements set in the file layout. Testing will begin in the fall of 2019.
- How will contribution due dates and related penalties be affected by this new reporting method?
TRS is updating the Administrative Code to reflect the changes in employers’ expected reporting frequency. Once these new rules have been established TRS will communicate them to all employers.
- When will testing begin?
The target date is the fall of 2019. TRS will notify all stakeholders once we are ready to accept test files.
- Will testing be for vendors only or can employers participate as well?
Vendors will be expected to test with TRS as well as any district who does in-house programming. If your district uses a vendor outside of the current vendor work group, we ask that you communicate with them to make the required changes. The current vendor work group includes Skyward, Power school, Tyler Technology (Infinite Visions), SDS, CIMS, Alio (Weidenhammer), RDA Systems, Decision Systems, ADP, Harris School Solutions, and Software Unlimited.
- Why is TRS not allowing the acceleration of contributions to be withheld and remitted to TRS?
One of the goals of this new reporting method is to be able to validate data at the time it is reported. By not allowing acceleration of TRS contributions, TRS is able to validate the 9% contribution on an individual basis and will enable employers to reconcile more frequently. This will allow for consistency in reporting for all members.
- How will the TRS mandate regarding the acceleration of contributions affect employers for whom the acceleration of contribution withholding is collectively bargained? Will this affect the grandfathered status of the agreements with regards to the new 3% FASCAP limits?
TRS is updating Section 1650 of the Administrative Code to not allow for the acceleration of TRS contributions. Once this rule is in place, it will take precedence over any collective bargaining agreement. In doing so, there will be no effect on a CBAs grandfathered status for FASCAP.
- Why will TRS now be collecting information on retired members?
Currently, TRS has no way to track retirees to know whether they have exceeded post-retirement limits. With the new payroll file, TRS annuitants will be reported to ensure if an annuitant is close to the limits, we can notify both the annuitant and the district to assist the annuitant with not exceeding the limits. If the annuitant exceeds the limits, we can ensure his/her retirement benefit is stopped in a timely manner and we can assist the district with correct reporting.
- Why does TRS want non-contributory earnings reported? Does this mean I have to report all my non-TRS covered employees to TRS?
TRS wants noncontributory earnings reported for members who are also working in a TRS-covered position, so we have a record we can go back to if concerns of unreported service are brought up by the member. TRS is only requesting that employers include noncontributory earnings for any members who also have contributory earnings to report in the same reporting period. Employees working in an IMRF position who did not also work in a TRS-covered position in the same period should not be reported to TRS.
- How often do I now need to report to TRS?
Employers will be required to inform TRS of their preferred reporting frequency of their payroll data. Employers will have the option of reporting per-pay period or reporting monthly. Once an employer chooses a reporting frequency, they must submit the appropriate number of reports based on their selection. For example, if an employer chooses to report per-pay period, the employer must report separate files for each pay period based upon the payroll schedule they submitted to TRS at the beginning of the fiscal year. Those who chose to report monthly must include all payrolls that occurred each month in a single monthly report. Once the voluntary Defined Contribution plan is implemented, those members who are enrolled in the plan must have their DC information reported every pay period to comply with federal defined contribution plan requirements.
- Can I change my reporting frequency, and if so when?
Payroll reporting frequency changes are allowed at any time throughout the year.
- If a payroll calendar for a district is geared towards hourly employees and is two weeks in arrears (Example, 8/16 – 8/31 payroll has a pay date of 9/14) but these same dates are used for contractual employees, the district would be reporting 0 days on the first pay period of the year assuming the contractual teacher school calendar started 9/1. Is this ok or does TRS expect a separate schedule for contractual employees?
TRS expects employers to submit each separate payroll schedule they use for different populations of employees. Employers will have the ability to submit their payroll schedules using the TRS Employer Portal.
- If an employer uses an annual payment option for some stipends/bonuses due to tax concerns (taxes are computed on an annualized amount), will TRS allow for an annual payroll frequency? For example, if $2,000 is paid as a lump sum on a semi-monthly basis, taxes are computed on $24,000, if it’s paid on an annual frequency, it’s figured as $2,000.
In submitting your payroll schedules to TRS, you will have the ability to flag certain pay periods or add extra pay dates for special payrolls like in the above example.
- How will federally-funded salaries be reported in the new system?
Federally funded contributions will not be collected on an individual basis. Within the per-pay period reporting process, you will be given the opportunity to report the total federally-funded contribution as one lump sum at the employer level.
- Will an error with one member/record cause my entire file to be rejected?
No, errors or edits within an individual member record will just reject that record or require further action on your part regarding that record’s contents. Errors in the header of a file that prevent us from positively identifying the employer or the period to which the report applies will cause the whole file to be rejected.
- We have several employees hired as paraprofessionals that are IMRF positions. Occasionally, they will substitute teach in a certified position. Are districts going to report their annual IMRF position wages just when they substitute teach?
When a paraprofessional substitute teaches, the substitute teaching days and earnings are reportable to TRS. In addition, on the same pay period when they substitute teach, the paraprofessional wages will be reported as noncontributory earnings.
- Similarly, for retired members who come back to work in a full-time paraprofessional position all year and occasionally substitute teach, is the district going to report their IMRF position wages when they substitute teach?
When a TRS annuitant returns in a TRS-covered position (i.e. substitute teaching, homebound teaching, etc.) the hours and earnings will be reported as a contribution category of 99 – Retired. Only work that counts against the post-retirement employment limitations would be reported. This will allow TRS to notify the member and employer if/when the post-retirement employment limitations are exceeded.
- We have certified employees who go on unpaid FMLA for a certain period which could be several days or months. Currently, their salaries are reduced by the number of unpaid days but they continue to get paid every payroll based on the new reduced salary. They will never be without a paycheck, but when they are paid, they are not working any days. How will this be reported?
The days paid would be reported as 0 since there are no days paid in that pay period and the earnings that are being paid would be reported as base earnings. This will likely invoke an edit that you will need to review and ensure the days and earnings have been correctly reported. In addition to reporting base earnings with 0 days paid for this member, you will report as LA (Unpaid leave of absence) for days that the member is on an unpaid FMLA. You will report days under LA even though the teacher is being paid earnings in that pay period due to the salary earned for days worked prior to the unpaid leave of absence being spread out over the remainder of the school year.
- How will dock days be reported for teachers’ whose docks are spread out over their remaining paychecks?
For the teacher who is docked but the salary is spread out over the remaining pay periods, the amount paid will be reported each pay period. For each pay period, you will report the number of days paid as the number of days the teacher worked and/or used accumulated sick, vacation and personal leave days. If you are spreading the teacher’s pay out over the remainder of the year, you may have pay periods in which you report earnings but 0 days. Docked days will be reported as docks in the pay periods in which the docking occurs.
- Teacher pay for miscellaneous extra duties are processed two weeks behind their current paychecks. Will the extra duty be required to be reported in the pay period earned?
Extra duties will be reported in the pay period in which payment is made using payment reason of ED (extra duty).
- If districts are not able to accelerate the contributions, but all contributions are still required to be submitted by July 10th, is the district required to pay the upcoming deductions or benefits for July and August before they are collected through payroll?
As long as TRS is on an Annual Reporting basis, it will not matter if employers accelerate contributions or not, but once we move to the new reporting basis, accelerating is no longer conducive. TRS and employers need a way to validate the 9% contributions every pay period. The only way to do this validation is to consistently report and submit 9% of earnings to TRS.
As always, all the contributions for each fiscal year are due to TRS by July 10th. To allow employers to remit the appropriate contributions to TRS by this deadline, they should report all their payrolls that will cover the work performed during the fiscal year at the end of June/beginning of July using the deferred flag, even if they will not be paying their members until July or August.
This can be achieved several different ways.
A. Run all checks at the end of June/beginning of July to ensure the contributions are remitted by the deadline and the earnings are reported as deferred on the pay period report. The checks can be held and paid in July and August or paid to the teachers in June.
B. Do not pay the teachers the earnings until July and August as you always have but report as deferred earnings the pays that will be paid in the summer months on the payroll report that is due July 10th. However, in this case the district would need to pay the contributions from district funds to ensure all contributions are received by the due date and not remit to TRS the contributions when they are withheld from the teachers’ remaining checks.
C. Pay all teachers over 10 months so that all salary is paid out by the end of June instead of over 12 months.
Member contributions will be balanced with each report to make sure that TRS has received no more or less than the applicable member contribution rate of the reported creditable earnings.
- How do we report earnings if our district pays the employee 9% contribution on the employee’s behalf?
When a district pays a member’s TRS contributions, the board-paid contributions are reportable as creditable earnings and should be included in the earnings reported on the payroll file. On the payroll file the earnings are broken out by payment reason instead of being reported as one number as it is currently on the Annual Report.
Example: The district pays the full 9 percent retirement contributions on all earnings. A member has a base salary of $50,000 / 24 = $2,083.33 and is paid $750 for a coaching stipend in a one pay period.
The amount report as base earnings (bs) would be 2,289.37 (2,083.33 x 1.098901) and extra duty (ED) of 824.18 (750 x 1.098901).
- How will districts report the time a TRS annuitant has worked?
Annuitants’ time worked will be reported in hours. Full days are converted to hours and a full day never counts for more than five hours. On days that the annuitant works less than the full day, all time he/she is required to be present should be counted.
Example 1: An annuitant teaches two 45-minute classes but is required to be in class 10 minutes between classes and 10 minutes before and after class. On this day a total of 2 hours is counted against the post-retirement limits.
Example 2: On Monday an annuitant works a full 7-hour day, on Tuesday he works 2.25 hours, on Wednesday he works 3.5 hours and on Thursday he works a full day. For this annuitant 15.75 hours would be reported.
- What if the contributions I submit do not equal the amount TRS expects to receive based upon my reports?
You will have to correct the discrepancy. The proper method for making these corrections or adjustments is still being determined.
- How will adjustments to previously reported information be handled? Does the procedure change when adjustments are for large stretches of time or cover a period prior to the implementation of the new, more frequent reporting method?
Full procedures for adjustments are still being determined. Regarding larger scale adjustments, the plan is to provide employers with a separate method for smoothing the change over a range of time, rather than submitting several different per-pay period adjustments.
- How do I know if a member is Tier 1 or Tier 2?
Tier status is determined by TRS. Currently, we plan to push the tier status of members to their employers before the start of the new reporting method. When hiring new members, employers will be able to look up the tier of the new employee via the TRS website as they can now. Finally, if an employer reports an employee’s tier incorrectly, we will notify them, so they can make the correction.
- What should be reported in the Days Paid field?
The Days Paid field should reflect the actual number of days paid covered for the pay period reported inclusive of days worked, and use of sick leave, personal leave, or vacation time. Days Paid should always be a whole number and partial days must never be combined to make whole days. Any portion of a day worked counts as one paid day. The days paid will not tie to the earnings that are being paid each pay period.
- How will earnings be reported in the file layout?
For each pay period, you will breakdown the amounts paid by payment reason and will report the actual amount paid.
Example: a teacher has an annual salary rate of $50,000 and is paid $2,083.33 each pay period for 24 pays. In addition, the teacher is a coach and the coaching stipend is also paid over 24 pays ($104.17 per pay) and occasionally does timesheet extra duties such as internal substitution and chaperoning. For each pay period, you will report a payment reason of BS (base salary) of $2,083.33 and ED (extra duty) $104.17 plus any timesheet extra duties paid. In June/early July, you will report the amounts the teachers will be paid in July and August for their base earnings and any contractual extra duties that are spread out over 24 pays and you will check the deferred flag.
- How do I report the Days Paid for members teaching summer school who are also currently receiving summer pay for the previous school year?
Days Paid for work a member is doing for summer school in June, must be reported under a record with the Payment Reason of SS (Summer School). Days Paid should reflect the actual number of days the member worked summer school for that pay period. Earnings for the work the member did during the regular part of the school year that are being paid out to them now would be reported as Deferred with Zero Days Paid.
- Will I need to report the Days Paid for Substitutes and Hourly members every reporting period?
TRS will expect actual days paid for both substitutes and part-time noncontractual or hourly employees. Keep in mind that any portion of a day counts as one day for service credit reporting purposes. You should not combine partial days, nor should you count the same day twice.
- How do I report those who have exceeded IRS or Tier 2 salary limits?
When a Tier 1 member has exceeded IRS 401(a)(17) limits or a Tier 2 member has exceeded Tier 2 salary limits, for the remainder of that fiscal year, that member’s earnings should be reported in the Earnings that Exceed Salary Limits field.
- What should I report for a member’s Employment Begin Date?
The member’s Employment Begin Date should be the first day that employee has reported to work. It is not necessarily the hire date.
- What do I do if a member is in more than one Employment Type in the same pay period?
If a member works under more than one Employment Type in the same pay period, you should report the “highest” Employment Type according to the following hierarchy: Full-time, Part-time contractual, Part-time noncontractual or Hourly, Substitute, and Extra-Duty.
- What should be included in Full Annual Rate?
This field should only be reported for members who are full-time or part-time contractual. For full-time members, include the member’s full year salary rate including employer-paid member retirement contributions. Exclude creditable earnings paid for extra duties, flexible benefit plans, or severance/lump-sum payments since they are reported separately. For part-time contractual members, the full annual rate should reflect what the member would earn performing their part-time duties for a full year, not what they would earn if they are working full-time.
- Am I supposed to include board paid TRS in the earnings that I am reporting?
Yes. You should always include any employer-paid member retirement contributions in the earnings you report on the file. Do not include employer contributions (0.58%) or employer-paid THIS Fund contributions.
- How do I report members who are on an unpaid board approved leave of absence?
You should report members who are on an unpaid board approved leave of absence by using the LA (leave of absence) payment reason. While reporting a member on a leave of absence, you must report the days the member is missing using the Days Paid field. For example, if a member is on a leave during pay period, and during that pay period they would normally have worked 12 days, you would report 12 in the Days Paid field to indicate the days they missed.
- If a district spreads out Extra Duty (ED) pay over 24 pay periods, should the ED also be reported as Deferred (D) for July and August?
Yes, the Deferred field should be flagged ‘yes’ while keeping the payment reason field as Extra Duty (ED).
- Do districts use the Sick Leave/Personal Days field to report what a member accrues throughout the year?
No. This field should be used to report a member’s current useable balance of sick leave and personal days (if personal days are useable as sick leave at your employer).
Example: if a member went into a new reporting period with 10 days, earned two, and used one, then you should report their available balance of 11. When a member terminates employment, you will need to verify the member’s ending balance of sick and personal leave days.
- Are corrections required to the Sick Leave/Personal Days field if a day is used but was not reflected on the report?
Districts will report the current balance of sick and personal leave days each pay period. No adjustment will be required if the balance is incorrect due to not all used days being reflected in the correct pay period.