IMRF Employer Compliance FAQs

Solicitud de Beneficios por Incapacidad

Frequently Asked Questions

Q. How long will the compliance review take?

A. It generally takes 1‐3 days to complete testing. However, this testing may take more time depending on responsiveness of the Employer, and any additional information or documentation needed. The compliance report is issued within two weeks of the review and the findings should be resolved within two weeks of completion of compliance testing.


Q. Who will receive the compliance report?

A. The compliance report is issued to the Authorized Agent and Executive Management such as COO and Superintendent of School Districts.


Q. Why was my Employer selected for a Compliance Review?

A. IMRF’s goal is to reach all employers. Your employer has been selected based on multiple criteria such as the date of the last compliance review, location, and employer size. Employer compliance reviews are considered best practice for public pension funds. Compliance reviews help ensure employers avoid liability by inadvertently violating employees’ pension rights.


Q. What is my role as an Authorized Agent in the compliance review?

A. The Authorized Agent should ensure the appropriate staff collect the items on the document checklist in a timely manner to prevent delays with testing. This includes other entities reported by the employer (e.g., library, special education district, etc.). The preceding year’s Social Security W‐2 txt file and 1099-MISC Forms should be submitted via Employer Access within the week following receipt of the appointment email. Other items listed in the document checklist should be submitted as they become available but no later than the scheduled compliance review date. Waiting until the date of the compliance review to provide the requested documents can delay the review process.


Q. Who should I notify at my Employer of the compliance review?

A. Please reach out to other employees who will be integral in completing the compliance review and/or anyone who is responsible for the result or resolution of compliance findings. This may include payroll personnel, finance personnel, accounts payable, Superintendent, or City Manager.

Q. Do I need to submit the W-2s of employees who are not participants of IMRF?

A. Yes. We are checking to validate individuals are properly enrolled and reported to IMRF.


Q. Do the payroll reports requested need to include employees not participating in IMRF?

A. Yes. Complete payroll registers assist with the reconciliation of reported wages to IMRF.


Q. What are Resolutions?

A. Resolutions are documentation of official action taken by a governing body. For compliance purposes, resolutions reflect decisions made to include certain wages as IMRF earnings (such resolutions must be specifically permitted by Board action). 


Q. What are Section 125 deductions and what significance do they have with reporting of IMRF wages?

A. Please refer to the Authorized Agent Manual Section 6.60 F and use the "Resolution to Include Compensation Paid Under an IRC Section 125 Plan as IMRF Earnings" form (Available In Employer Access) as a sample. Instructions can be found on the Wage Adjustment Procedures page in the Employer Access Learning Center.


Q. If an employee works in a position that is not expected to meet the hourly standard but the employee begins to exceed the hours after the first year, how do I determine when to enroll this employee?

A. Please refer to the Authorized Agent Manual section 3.65 A Periodic Reevaluations and the publication "Should this Employee be Enrolled" when re‐evaluating a position.


Q. When the compliance finding recommends Omitted Service for an employee and the employer completes the "Omitted Service Credit Verification" form (Available in Employer Access), is the employee required to purchase the past service and is there a cost to the employer?

A. Returning the application for omitted service credit does not obligate the employee to purchase the service credit. After the member receives the payment schedule, they can review the cost, request a pension estimate via Member Access, and determine if this additional service will benefit their pension benefits. No immediate payment is required of the employer, but the cost will be reflected in future contribution rates.


Q. How do we resolve compliance issues?

A. Compliance Issues should be resolved by the date listed on the compliance report. Each issue provides a recommendation on the compliance report. If you have any questions, or need assistance, please contact your assigned compliance associate.


Q. If the Employer removes previous wages and terminates a member retroactively, does IMRF or the Employer reimburse the member for the contributions on file?

A. IMRF issues a credit advice to the Employer. The Employer is responsible for reimbursing the member their member contributions.


Q: How do I complete/submit Wage Adjustments?

A. Please see the Wage Adjustment Procedures area in the Employer Access Learning Center or contact the IMRF Wage Reporting Unit for assistance.