Introduction

Welcome to the Q&A recap from our 2025 Census Season Bootcamp. This session brought together three connected themes that are shaping census season right now: smarter regulatory readiness, cleaner data at the source through payroll connectivity, and modern census automation that can cut 75–95% of the time TPAs spend on data collection, scrubbing, validation, and client back-and-forth.

This was our most attended webinar yet, and the questions you submitted were outstanding—real-world, nuanced, and exactly what TPAs are wrestling with heading into year-end 2025 and early 2026. We received more questions than we could get to live, so we’re publishing the full set here for everyone to use as a reference throughout the season.

You’ll find answers spanning MAE and Roth catch-up details, LTPT data pitfalls, compensation definition validation, affiliated service group payroll handling, and practical implementation guidance on getting a modern census workflow live in time for January 2026—powered by payroll data and AI automation.

We hope this page helps you move faster, reduce risk, and make this your easiest census season yet. The answers to the regulatory questions are provided by Ilene Ferenczy of Ferenczy Benefits Law Center, the answers on payroll connectivity and data by Gayathri Somanath of Finch, and the questions on census process modernization and automation by me.

The questions are in the order in which they were asked during the webinar. If you missed the webinar, don't worry! We have prepared the "Census Success Kit": a takeaway that includes the deck and various resources including a regulatory cheat sheet, census communication templates, scrubbing checklist, and modernization timeline.

Download the Census Success Kit here.

How similar is the definition of employee for MAE the same as for Simples?

They are not the same.  The definition of employee for MAE purposes is anyone who is eligible to defer.  For purposes of determining how many employees a company has for purposes of the fewer-than-10-employee exemption from MAE, an employee is a common law employee (not including sole proprietors, partners, directors (acting as such, and independent contractors).  People who work fewer than the number of hours to be full-time (usually 40, but could be less) are considered to be a fractional employee.  Employees for SIMPLE purposes, to determine if the employer has 100 or fewer employees, is an employee who received at least $5,000 of compensation in the prior calendar year.

If a plan started in 2017 and currently has 10+ employees, is MAE applicable?

If the plan had a 401(k) feature in place before 12/29/2022, it is grandfathered and is not subject to MAE, regardless of the number of employees.  Check out the ERISApedia.com webcasts – there is a good one on MAE.

The regulations seem to say that the Roth catch-up requirement does not apply to catch-up contributions if the participant has already made Roth contributions greater than or equal to to catch-up amount. Is that correct? For example, if a catch-up eligible participant contribes $2,000 per month where half is Roth and half is pre-tax they will have contributed $12,000 in Roth already so that they will not be required to do Roth as the catch-up.

Under the final regulations, this is an option for the plan sponsor.  Some plan sponsors, as well as payroll companies and recordkeepers, are either unwilling or unable to go back and check when someone hits the $24,500 402(g) limit to determine if the person has prior Roth contributions that can take the role of the catch-up contribution, allowing someone to continue to defer on a pre-tax basis.  Before you assume that this is the case, check the plan and check with the client and its systems people to see what can be effectively done.

Do we have to do benefits, rights, and features testing if the plan allows for catch-up deferrals but not Roth contributions and therefore HPI are not allowed to make catch-up?

If you have non-HCE HPIs and non-HPI HCEs, there is a potential for a BRF problem.  So, say that Ilene is a partner in a partnership and is an HCE.  She is not an HPI, because she has no FICA wages.  Assume further that she has one employee:  her office manager makes $152,000 in FICA wages.  The office manager is a non-HCE HPI.  Ilene can make all the catch-up contributions she wants, because the Roth rules don’t affect her. The office manager, on the other hand, is not permitted to make catch-ups because Roths are not allowed in the plan.  Because “all” the HCEs can make catch-ups and “all” the NHCEs cannot, we have a discrimination problem. The IRS suggests in the regulations that the plan be amended to provide that any HCE who is not an HPI but would be if his/her compensation were FICA wages be prevented from making catch-up contributions to solve the problem.

So...even though Self Employed income IS subject to FICA, it is not considered FICA wages?

Self-employed people do not pay FICA through payroll withholding.  It is paid as part of the income tax return the individual files.  So, it’s not “FICA comp” for purposes of withholding.

For a plan allowing Roth and catch up contributions - Is benefits, rights, and features testing required if an employer does or does not aggregate compensation of related employers?

No.

Do they need a separate asset/investment account set up for ROTH ?

The law requires that Roth amounts are segregated and separately accounted for.  If the fund is pooled for investments, that’s fine, but it must be segregated out in the participant accounting.

Are there communication templates for TPAs to send clients on the Roth catch up change and the 60-63 updates?

The Ferenczy Benefits Law Center is selling policies and procedures (required if you need to make any corrections), and it has a notice to highly paid employees affected by the Roth rules in it.

What is the best way to handle payroll in an affiliated service group? For example, the law firm of Smith, Jones & Green, LLP employs 5 while Smith, Jones, and Green each have their own LLCs.

Each entity needs a separate payroll connection as they have their own employees and payroll provider. You can create the other entities as companies in CX, set the status to “Active” to collect payroll, and then change to “ASG” to avoid being treated as a separate client. You can use custom company data fields or tags to link affiliated service groups.

Do payroll uploads from non-accessible payroll companies need to be spreadsheets or could they be pdfs?

Currently, they need to be spreadsheets (XLSX, CSV, etc.), but Stax.ai is actively working on functionality to support PDF payroll reports.

Does the census get compared to recordkeeper data for contributions?

Yes, recordkeeper reports can be uploaded in the plan assets section and any reconciliation discrepancies will be flagged. The trust reports from recordkeepers will also be used for testing and 5500s.

For LTPT workers eligible in 2025/2026, how should TPAs handle cases where the plan sponsor’s payroll system rounds or buckets hours, potentially creating eligibility discrepancies?

You need your client to reconcile differences, unless there is something in your service agreement that makes you responsible.  You should tell your client what you need, and give them the opportunity to get you correct data. This is why, by the way, it’s so important to PREPARE your clients for the information you will need.

How should TPAs reconcile conflicting hire dates, especially when rehire dates overwrite original dates in payroll systems—what is the proper compliance approach?

You cannot do this correctly without proper data.  If your client can’t give you the data, you can suggest to them assumptions to be made, but make sure it is at their own risk.  Also, I would make sure the assumptions work in favor of the participant.

How quickly can a TPA implement Stax.ai’s census automation workflows, and is there enough time to be fully ready for January 2026?

If you start before December 15, 2025, you will be able to onboard for census only using an accelerated timeline to have collection requests go out on December 31, 2025.

How does the system track and calculate LTPT eligibility automatically, especially for plans transitioning into the SECURE 2.0 requirements?

When payroll data is synced with Stax.ai CX, the platform receives all pay statements from the last three years - which include hours worked (unless not recorded on the payroll system). Using these hours, LTPT calculations are performed automatically.

Under the Roth Catch-Up mandate, how should TPAs address census files that omit or incorrectly categorize FICA wages—can testing still proceed, or must sponsors correct and resubmit?

Assuming that the only use of the FICA wages is for HPI determination – that is, that you have correct compensation for testing ADP, etc. – you can go forward with the testing.  It’s the correction that will be affected by the HPI rules – whether ADP failures can be reclassified as Roth/catch-up or not, or 402(g) excesses, or 415 excesses, or plan excesses.  So, testing is OK, correction is not.

Does the payroll feed include FICA wages, and will that be available in time for 2025–2026 testing cycles?

Yes. Beginning with the 2025–2026 testing cycle, Finch will provide W-2 Box 3 (Social Security wages) and Box 5 (Medicare wages) for all payroll providers where this data is available. Finch is currently working on developing this enhancement that aligns with the expanded data needs for Roth catch-ups and will be included in the standard payroll feed in 2026.

How many payroll providers are currently supported for integrations, and which of the major national providers are included?

Stax.ai CX uses Finch, which supports 250+ payroll providers, covering 80%+ of the U.S. payroll market. This includes all major national providers - ADP, QuickBooks, Gusto, Paycom, Paylocity, Paychex, UKG Pro, UKG Ready, Workday, Trinet, and many others. You can view the full list here: https://developer.tryfinch.com/integrations/providers. 

With more than 600 providers in the U.S., many of them niche or regional, Finch also supports on-demand addition of new providers. Stax.ai works with Finch to enable new providers as needed. For details on requesting new integrations, see: https://support.tryfinch.com/articles/8555609223-how-to-request-new-integrations

When plan documents define compensation differently for eligibility, allocations, and testing, what is the recommended method for validating which compensation fields should be included or excluded in the census file? We always just asked for eligible compensation in spreadsheets, but we've seen that a lot of that can be incorrect.

Well, this question highlights the difference between TPAs who try to provide the highest level of service to their clients and those that follow a lower level model.  There’s nothing necessarily wrong from a business liability standpoint with either service model, so long as your service agreement and your client advice matches what you are doing.  I will leave it to you to decide if there is anything wrong with a service model from a moral standpoint – i.e., is it okay to put responsibility on your client if you don’t give them the tools they need to give you the correct answers?  

If you expect your client to know what is included in their definition of compensation without help from you, you are barking up the wrong tree.  (And, if you want an illustration of that, ask your staff administrator’s what comp is includible in W-2 definitions, and you will find they have never read the document; on that basis, how can you expect that your client would?)

So, here are some options (but be sure to check what your service agreement says:  (1) YOU figure out what compensation categories are includible for each compensation definition and have the client give you a complete payroll dump, and you identify includable compensation from the categories on the payroll dump; (2) YOU figure out what compensation categories are includible for each compensation definition, you get the client to provide you the payroll categories that they have, and you tell them which categories you need and how they need to be reported; (3) like #2, but you have them calculate compensation for each use; (4) you provide them with a list of includible compensation and have them figure out which categories in their payroll system match the definition and report it to you; or, the worst choice of the batch:  (5) you say in your service agreement that calculating proper compensation is their responsibility and you’re not responsible, and just take what they give you, knowing that it will blow up in an audit, but planning to rely on your disclaimer in your contract.

When pulling data from payroll, how do you get eligible compensation? This is usually never in payroll files.

That is correct, however Stax.ai CX has the plan provisions from the adoption agreement which indicates how eligible compensation should be calculated. These provisions are used to map the payroll codes accordingly to handle exclusions from gross compensation.