The 2026 Roth Catch Up Rule for Utah Physicians 50 and Older

The skinny

• What happened: Starting in 2026, if you're 50 or older and your 2025 Social Security wages (W-2 Box 3) from the employer that sponsors your plan were over $150,000, your catch-up contributions to a 401(k), 403(b) or governmental 457(b) must go in as Roth.
• Why: Congress wrote the rule into SECURE 2.0 in December 2022. The IRS transition period generally ended on December 31, 2025, so 2026 is the first year it bites.
• How it changes things for you: If your plan offers Roth, you can still contribute the full amount. You just lose the deduction on the catch-up portion. If your plan has no Roth option, you can't make a catch-up in that plan.
• Do you need to do anything: If the rule applies to you, check before December 31. Find Box 3 on your 2025 W-2, confirm on your paystub that your catch-up is coded Roth, and ask HR for your last 2026 pay date, because catch-ups must go through payroll before the plan year ends.
• Who it doesn't affect: Anyone under 50 at year end, anyone below the $150,000 line at the employer that runs the plan, partners paid only on a K-1, and, in the new plan, anyone who joined an unrelated employer in 2026.

Education only, not tax advice.

This guide walks through the final regulations so you don't have to. It's about as fun as it sounds.

Does the $150,000 test apply to me?

You're in if both of these are true.

• You'll be 50 or older by December 31, 2026.
• Your 2025 W-2 Box 3 wages from the employer that runs your plan were over $150,000 (IRS Notice 2025-67).

If you're over the line, your 2026 catch-up has to be Roth. If your plan has no Roth option, you can't make one.

Box 3, not Box 1. Your pretax 401(k) and 403(b) deferrals come out of Box 1, but they stay in Box 3 (26 U.S.C. §3121(v)). So a doctor who deferred heavily may still be over the line.

Per employer, not per household. Your spouse's income doesn't count. Neither does money from a second employer.

What are the 2026 limits?

$24,500 basic, plus an $8,000 catch-up, or $11,250 if you turn 60, 61, 62 or 63 during 2026 (IRS IR-2025-111). The basic limit covers a 401(k), 403(b) or governmental 457(b), and the Roth rule covers the 60 to 63 catch-up the same way.

How does it work at the University of Utah?

If you're paid through University payroll, you get two catch-ups, and the switch to Roth is automatic.

• Two catch-ups. The U offers a 403(b) and a governmental 457(b), and you can contribute the IRS maximum to each (U of U Benefits). That means $16,000 combined for 2026, or $22,500 combined if you're 60 to 63. Both are subject to the Roth rule.
• Automatic switch. Per the U, once W-2s are finalized, HR notifies employees who are subject, and the U's system converts pretax contributions to Roth once you've hit the basic limit (U of U Benefits). Your base $24,500 can still be pretax.
• Exactly $150,000? The U's pages conflict on that case, so ask UHRM which test their payroll applies.
• VA appointment? Per the U, your contributions to the VA's Thrift Savings Plan count toward your U 403(b) limit. The Roth wage test still runs per employer (TSP bulletin).

How does it work at Intermountain Health?

The 401(k) has Roth, so if you're over the line, your catch-up there goes in as Roth. The 457(b) doesn't allow age 50 catch-ups, so the rule doesn't touch it.

• The 401(k) offers both pretax and Roth contributions, and your Intermountain 403(b) deferrals count toward the same limit (Intermountain 401(k) SPD).
• No public notice yet. I couldn't find a public Intermountain notice on how it's implementing the 2026 rule. Check your paystub and ask HR.
• The 457(b). Intermountain is a 501(c)(3) (Intermountain), so its Key Savings 457(b) is non-governmental, and non-governmental 457(b) plans don't allow age 50 catch-ups at all (IRS). The IRS also notes those assets stay available to the employer's general creditors. If you have that plan, understand how it works before you put money in.

What about private groups and K-1 partners?

How you're paid decides it. Partners paid only on a K-1 are out, and W-2 pay counts.

• K-1 partners. If your only income from the practice is partnership income, you have no Social Security wages from it, and the final regulations say you're not subject to the Roth requirement. Your catch-up can still go in pretax if the plan allows it.
• S corporation owners. The salary you pay yourself is W-2 wages (IRS), so if it topped $150,000 in 2025, you're in. Distributions don't count, but talk to your CPA before you rework your salary.

Is a Roth catch-up a bad deal?

Not automatically. This section is education, not tax advice. I'm an investment adviser, not your CPA.

• The catch-up money is included in your income now. Qualified withdrawals later come out without federal income tax (IRS).
• A withdrawal is qualified once the Roth account has been open five years and you are 59 and a half or older, or in a few other cases.

Questions to bring to your CPA:

• Where does my catch-up land in my bracket this year?
• Would the deduction be worth more to me now than money I can take out without federal income tax later?

Skipping the catch-up is a choice you can make. It does not bring the deduction back, because that pay is taxed either way. Just make the choice on purpose.

What should I check before December 31?

Your W-2, your paystub and your last 2026 pay date. At the U, check both plans.

1. Pull your 2025 W-2. Find Box 3 for the employer that runs your plan.
2. Check your latest paystub. Confirm the catch-up is coded Roth if you're over the line, and check year to date deferrals against $24,500 plus your catch-up.
3. Find your last 2026 paycheck. On the U's 2026 payroll calendar, which the U marks subject to change, the last pay date in 2026 is December 22. The pay period ending December 31 is paid January 7, 2027 (U of U Payroll). Ask UHRM which paycheck counts toward your 2026 limits. At Intermountain, ask HR for the same two dates.
4. Coded wrong? Ask payroll now. Plans can fix it with a W-2 correction or an in-plan Roth rollover, and the W-2 route only works before your W-2 is filed or furnished.
5. Tell your CPA. Roth catch-up money is included in your taxable wages.

What about 2027?

The rule stays, and the dollar limits are adjusted for inflation each year. As of November 3, 2026, the IRS hasn't published 2027 limits. The test for 2027 will use your 2026 Box 3 wages, against a threshold the IRS will set. I'll update this page when the IRS publishes them.

The final regulations generally apply starting in 2027, and some governmental plans can get a later date tied to the close of a legislative session. Neither date delays the rule itself.

Where should I start?

With what costs you nothing. Pull the W-2, check the paystub and send HR one email.

If you'd like to talk through how the catch-up fits with the rest of your finances, reach out to set up a time to talk. There is no cost, you don't have to hire me, and I will send you my Form ADV first. A call, lunch, fifteen minutes, or I'll come to you.

Since you'll ask how I'm paid, Harvest Lane is fee only. For investment management, the fee is a percentage of assets on a tiered, blended schedule, so each rate applies only to the assets within its tier. Standalone planning is billed by the hour.

Every fee, and the conflicts that come with them, is in Item 5 of our Form ADV Part 2A. If the labels in this industry blur together, this page sorts them out. Before you hire anyone, me included, run the checks in how to check if your financial advisor is a fiduciary.

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