If we had to pick two points when it’s critical to get the most granular, accurate, and complete data about your workforce, it would be during the initial and annual census file collection. This article explains what we need for your initial census file and why we need it in order to onboard your plan to our platform. Please review our Annual Census Data Guide and Annual Census User Guide to understand our requirements for your year-end census file collection. Also see our article Census Files: What Is Needed for Year-End Testing.
I never heard of a “census file.” What is it?
This is a file of all demographic data for your workforce. It includes employees’ names, dates of birth, date of hire and rehire, dates of termination, social security numbers, compensation, and job title/officer status.
That sounds like a lot of work. How do I get it?
Your payroll provider should have all or most of this information. Your Vestwell Representative will work with you to obtain these files in the format we need from your provider.
Which employees do I need to include in our census files?
Simply put, all of them!
Your census file must include all employees even if they don’t participate in the plan or work less than full-time. Your census file must also include all employees who worked for your company at any time during the year. Please see our Help Center article about “Determining Who is an Employee” because identifying who an “employee” is for purposes of your plan, especially for certain types of businesses, can be different than how you may treat them for your other workplace benefits. Including part-time employees is especially important because, effective January 2021, the SECURE Act (which was signed into law in December 2019) requires employees who work for 500 or more hours for three years to become eligible to participate in the plan. Even though those part-time employees will not become eligible until 2024, we need records of their employment starting in 2021.
Additionally, your census file must include all employees employed by any companies related to your company - regardless of whether or not that related entity is participating in your plan. This is required because all of those individuals may also be considered in the annual compliance testing for your plan, even if they are not receiving any benefits from it.
My company has seasonal workers, and some are rehired each year.
Include them in the census file, too. For example, the census file must include the original hire, termination, and rehire dates. And, if an employee was terminated and rehired multiple times, we need all of those dates. We need this level of detail to determine which employees are eligible and when they became eligible so that we can confirm that all employees who satisfy your plan’s rules are given the opportunity to enroll in the plan.
Can I estimate dates of birth, dates of termination, and/or dates of rehire?
Unfortunately, close enough is not good enough. We need exact dates because these dates can have significant downstream consequences for plan administration. A date of birth, for example, can determine when someone becomes eligible to participate in the plan, reaches a plan’s normal retirement age, or is required to take a distribution upon reaching age 72. A date of hire can affect participants’ vesting of their benefits. You get the idea - - even a small discrepancy can have a big impact on your participants.
As a reminder, Vestwell relies on the data you provide to us. We can’t onboard your plan or operate it smoothly without getting precise and accurate information from you or your payroll provider.
We hope you find this information helpful. If you need further assistance please contact your Vestwell representative.