Running the Scrub/Eligibility task for plan years ending on or after 1/1/2026 calculates Highly Paid Individual (HPI) status.
HPI status is determined by comparing the participant’s prior-year HPI Compensation to the current year’s HPI annual limit:
- If prior-year compensation exceeds the current limit, HPI is set to Yes.
- If it does not exceed the limit, HPI is set to No.
For plans that do not end on 12/31, the system applies the limit in effect at the end of the current plan year to the prior-year compensation. Note that compensation used for HPI determination is calendar-year compensation.
If a participant is identified as an HPI, the system will display the following warning in the Scrub/Eligibility section:
"The participant is classified as an HPI. Please review any catch-up contributions and, if necessary, reclassify them as Roth."
We also created the following grids for uploading current year HPI Compensation and reviewing HPI Status.
* ftw HPI Current Year Compensation Upload
* ftw HPI Status
To include the current year HPI compensation in your custom grid, use the field name:
R:HPICompensation
Off-Calendar Year Example:
For a plan year 7/1/2025–6/30/2026, the prior year is 7/1/2024–6/30/2025. The HPI compensation uploaded for this plan year should reflect the applicable calendar year HPI compensation. The current limit for 2026, $150,000, will be compared to the participant’s prior-year HPI compensation.