TRS outlines automatic enrollment, reporting duties for Supplemental Savings Plan

Melissa Keane, deferred compensation operations supervisor for the Teachers' Retirement System, on a TRS webinar explained how automatic enrollment into the TRS Supplemental Savings Plan (SSP) works and spelled out employer reporting duties and timing.

Keane said employees first employed in a TRS-covered position on or after Jan. 1, 2023 with a reported employment type of full time or part time contractual will be automatically enrolled at a default deferral of 3% of pretax compensation, invested in a target-date fund chosen by birth date, unless the employee opts out or changes elections prior to the contribution effective date. "The SSP is unique in that it was statutorily required to be created and maintained for the best interest of the participants," Keane said.

Why it matters: automatic enrollment creates immediate payroll and reporting tasks for school districts and other TRS employers. Keane emphasized that accurate information on the Defined Benefit report in the TRS employer portal (Gemini) — including correct employment type, Social Security number, date of birth and mailing address — determines SSP eligibility, PIN mailing and the timing of enrollment. "If we have incorrect information, that can impact the eligibility for SSP," she said.

Key facts and employer actions

• Eligibility and timing: TRS determines eligibility after the employer reports a new hire on the Defined Benefit report. Keane said TRS takes about three days to determine eligibility after the report posts; employees typically receive a PIN and enrollment packet about seven to 10 days later. The automatic enrollment effective date will be no less than 30 days from the first report; if the employee takes no action by that date, deductions begin.

• Employee choices and refunds: Employees may opt out or change their deferral amount or investment elections online using the mailed PIN or by calling Voya. If contributions have begun, an employee has 90 days from the first posted contribution to request a permissible withdrawal (a refund of contributions adjusted for gains, losses and fees). Keane cautioned that any employer matching contributions in the account at the time of a permissible withdrawal will be forfeited; non-elective employer contributions remain until a qualifying event. "They do have 90 days from when they were first reported to request a permissible withdrawal through Voya," Keane said.

• Reporting and funding timing: SSP reports should be posted in Gemini as close to the pay date as possible because contributions are invested immediately. Keane contrasted SSP reporting (calendar-year/IRS basis) with Defined Benefit reporting (fiscal-year basis, due by the 10th of the following month) and said districts should submit SSP reports on the pay date (or when the ACH is sent). For first-time SSP reporting, employers must provide their financial institution with TRS's ACH company ID; missing that ID can cause rejections and delays in getting funds to Voya.

• Deferrals report and monitoring: TRS issues an SSP deferrals report (salary reduction agreement/ SRA) listing new deferrals, changes and cancellations; it includes an "auto enrolled" indicator and a flag when a contribution category has met its annual limit. Keane said employers must begin deductions on the pay period that begins on or after the contribution effective date listed on the deferrals report and should not process changes until they appear on that report. TRS also sends a weekly delinquent-contribution email on Tuesdays listing the most delinquent pay date when expected SSP reports are missing.

• Contribution limits and catch-ups: Keane gave the 2025 regular 457 limit as $23,500 and described two separate limit tracks for SSP (regular contributions and age-based catch-up). Under SECURE 2 changes effective Jan. 1, higher catch-up limits apply for employees aged 60–63 (Keane cited $11,250). She also described the three-year special catch-up available in the three years before an employee's designated normal retirement age (a designation used only for catch-up eligibility and not to change actual retirement rules). Keane reminded employers that contribution limits include both employee and employer amounts, and that TRS will display a limit flag on the deferrals report when a limit is reached.

• Other plan features: Employees may elect to defer lump-sum payments for unused bona fide sick, vacation or leave to the SSP; the election must be completed with Voya before the lump sum is submitted on the SSP report. TRS and Voya provide participant resources at trsilssp.voya.com and TRS posts annual IRS limits on its website. Keane also introduced local Voya representatives (named in the webinar as Stacy and Terry) who can hold individual or group meetings.

Discussion vs. direction vs. decision

• Discussion points: Keane reviewed the automatic-enrollment lifecycle, employer reporting mechanics, contribution categories (pre-tax, Roth, employer match/non-elective), permissible withdrawal timing and catch-up rules. She answered questions in a Q&A segment.

• Directions to employers: Accurately report employment type, SSN, date of birth and mailing address on the Defined Benefit report; start SSP deductions only when the deferrals report indicates the contribution effective date and post SSP reports in Gemini as close to pay date as possible; provide the ACH company ID to the financial institution before the first SSP file upload; monitor the deferrals report and weekly delinquent notices.

• Formal decisions: No formal board votes or policy adoptions occurred during the webinar.

What TRS provided for follow up

Keane directed employers and members to TRS and Voya participant webpages for guides and forms, said TRS posts annual IRS limits on its website, and encouraged employers to contact TRS employer services (Gemini reporting/accounting contacts) or Voya for participant-level questions. TRS will mail PINs and enrollment packets to mailing addresses reported on the Defined Benefit report.

For employers: TRS advised adding or confirming "reporting" and "accounting" contacts in Gemini to receive deferrals reports and delinquent emails, and to process new deferrals or changes only when they appear on the deferrals report.

For members: employees identified for automatic enrollment may opt out at any time prior to the contribution effective date or later enroll if they previously opted out; they may also request a permissible withdrawal within 90 days of the first posted contribution.

Keane closed the session with links and contact information for TRS SSP support and the Voya SSP participant site (trsilssp.voya.com) and moved to a Q&A segment.