Refunded HCE Contributions and Missed Executive Deferrals Reduce Retention Value of Plans
Definition
When ADP/ACP tests fail, employers must refund elective deferrals and/or matching contributions to HCEs to bring their average percentage in line with NHCEs. These refunds lower HCEs’ effective annual deferral capacity and can discourage executive participation, reducing the perceived value of the plan as a key retention and compensation tool.
Key Findings
- Financial Impact: Commonly 5–15% of total HCE contributions for failing plans are refunded each year, which for a mid‑size insurance or benefit fund plan can mean $50,000–$250,000 in lost tax‑deferred savings value to executives and reduced long‑term retention benefit.
- Frequency: Annually in each year the plan fails ADP and/or ACP testing; roughly 30% of small‑business plans subject to ADP/ACP fail in a typical year.
- Root Cause: Plan designs that favor high HCE deferral percentages without sufficient NHCE participation, combined with lack of proactive modeling of testing results and failure to adopt safe harbor designs. Many sponsors view testing as an after‑the‑fact compliance exercise rather than managing it as a strategic benefits design issue, so HCEs repeatedly bump into the refund ceiling.
Why This Matters
This pain point represents a significant opportunity for B2B solutions targeting Insurance and Employee Benefit Funds.
Affected Stakeholders
Highly Compensated Employees and executives in insurance carriers, brokers, and benefit funds, CFOs and CHROs responsible for total rewards strategy, Benefits committee members and trustees, Financial advisors serving the plan
Deep Analysis (Premium)
Financial Impact
$50,000–$250,000 in lost tax-deferred savings and reduced retention value per year • $50,000–$250,000 in refunded HCE contributions and lost tax-deferred savings • $50,000–$250,000 in refunded HCE contributions and lost tax-deferred savings annually
Current Workarounds
Complex Excel models for HCE/NHCE projections and correction scenarios • Manual calculations and tracking of HCE vs NHCE contribution percentages in spreadsheets • Manual Excel aggregation from multiple contributing employers
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Methodology & Sources
Data collected via OSINT from regulatory filings, industry audits, and verified case studies.
Related Business Risks
Recurring ADP/ACP Test Failures Trigger Corrective Contributions, Excise Tax, and Disqualification Risk
High Recurring Administrative and Professional Fees to Fix ADP/ACP Errors
Data and Setup Errors Cause Mis‑Testing and Costly Rework of ADP/ACP Results
Delayed ADP/ACP Testing and Corrections Extend Refund and Contribution Cycles
Manual ADP/ACP Testing Consumes HR/Finance Capacity and Crowds Out Strategic Work
Testing and Correction Complexity Creates Window for Abusive Contribution Patterns
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