A.09 Missing DTL4 Records and Fees (formerly 8.02.04)

Marked obsolete 02/01/2018

OBSOLETE section - For reports before October 2015, an ORS audit found and addressed problems due to missing DTL4 records. For reports after that date, a missing DTL4 record causes the member's DTL2 record on that report to suspend, and the missing DTL4 record must be added before the report can be posted. For that reason, this section no longer applies.

The member 457 and employer 401(k) contributions for Pension Plus, Personal Healthcare Fund (PHF) and Defined Contribution plan employees are sent from ORS to the Third Party Administrator (TPA). ORS reviews your payroll reports to ensure that every employee who has a DC component to their retirement plan has the appropriate Detail 4 (DTL4) record.  After the report is posted and the records are matched with the associated contribution payment on the report, the employee's DTL4 record and contribution is then sent to the TPA. This means that whenever a DTL4 record is not submitted on time or is submitted incorrectly those contributions are not earning interest, creating potential financial loss for your employees. In addition, federal transfer laws concerning 457 and 401k plans require that Defined Contribution monies be transferred to the TPA within 15 business days of the end of the month in which the payroll is paid. To ensure and enforce ORS compliance with state and federal laws we assess fees for missing DTL4 records.

Detail 4 (DTL4) records for Pension Plus members are due on Retirement reports on the established ORS reporting schedule. See section 7.02: Report Due Dates for more information. To ensure that all DTL4 records and monies are transferred timely to the TPA be sure to post reports 100% and correct errors immediately and pay contributions by the due date. See section 8.02.01: Payment Due Dates for required payment due dates.

It is important to note the following:

• Detail 4 records are required for all Pension Plus members. If the member has elected to opt out of the DC portion of the plan, a DTL4 record is required for each pay period up to the date in which the opt out change is provided to the employer by the TPA*.
• Detail 4 records are required for all members who first worked on or after September 12, 2012 and elected the Defined Contribution plan. If the member has elected to opt out of the DC, a DTL4 record is required for each pay period up to the date in which the opt out change is provided to the employer by the TPA*.
• Detail 4 records are required for all members with the Personal Healthcare Fund (PHF).  If the member has elected to opt out of the PHF, a DTL record 4 is required for each pay period up to the date in which the opt out change is provided to the employer by the TPA*.
• Detail 4 records are required to report the mandatory 4% DC employer contribution for members who converted from MIP or Basic to Defined Contribution in the reform election effective in February 2013. This mandatory deduction is required as long as the member has wages reported to ORS.
• Detail 4 records submitted with incomplete information or inaccurate begin and/or end dates are considered missing. For example if the contribution field was left blank, the record is considered missing. If the begin and/or end dates on the DTL4 do not match the begin and/or end dates on the DTL2 record then the record is considered missing. Please ensure all DTL records are submitted accurately.

*Only one DTL4 record per pay period is needed to report both DC and PHF if the member has both types of contributions. Any member changes to DC and or PHF contribution percentages is relayed to the reporting unit via the DC Feedback File link on the employer reporting web site.

ORS currently assesses a fee when a missing or incomplete DTL4 record is identified and then sends each employer a list of records considered as missing or incomplete. This list is called the missing DTL4 record report. Effective with the first missing DTL4 record report of 2014, a permanent fee will be assessed if the records listed on the missing DTL4 record report are not corrected by the 5th business day of the second month after the reporting unit was notified.

For example, all missing or incomplete DTL4 records identified for January must be completed by the fifth business day in March to avoid any fee. If the records are not fixed within this timeline then a permanent $50 fee per report end date will be assessed.

For further information about DTL4 records see section 7.21: DC Contributions.

Last updated: 02/01/2018