Zero-balance 403(b) staff may still count on Form 5500, Groom attorneys say

Changes effective in 2023 generally exclude eligible employees with zero account balances from the participant count that decides large- or small-plan filing status, Groom Law attorneys write in PLANSPONSOR. Groom's Benefits Brief summarizes the column by Kimberly Boberg, Kelly Geloneck, Emily Gerard and David Levine, which addresses how 403(b) sponsors should count participants when preparing Form 5500 filings.

Those same employees may still need to be included in other participant counts on the form, the attorneys say. They stress following the instructions for each line.