Reporting Requirements
Reporting Requirements
Employer Responsibilities
- Report the name, SSN, time worked, and gross earnings of each employed member or working retiree each month;
- Pick up (i.e., withhold) contributions from each employed member's TRS-includable salary on a tax-deferred basis and remit those contributions to TRS each month;
- Remit employer contributions to TRS at the rate specified in TRS law;
- Inform each new employee of their rights and obligations as a member of the retirement system; and
- Provide information to TRS as required for accurate administration of the retirement system.
TRS Wage and Contribution reports are due to TRS by the 15th of the month following the month in which wages were earned (not paid).
More procedural tips and resources are provided below to help with accurate reporting.
TRS has two employer reporting systems:
- The Wage and Contribution Reporting System, used for monthly reporting of TRS members' hours and wages and for remitting employee and employer contributions to TRS.
- The Insurance Deduction System, used by some districts to report health insurance premium amounts for retired TRS members who remain covered on the district's health insurance plan after retirement. If the retired member signed up to have their self-paid premiums deducted from their TRS retirement benefit, this system allows you to report that amount to TRS.
One person in your district or organization must be the designated online administrator for TRS reporting purposes. Often it is the district clerk or payroll clerk.
If your district uses both of the reporting systems described above, one person may be the online administrator for both systems. In bigger districts, a different person might be the main contact for Insurance Deduction System reporting duties.
- Sharing of usernames and passwords is a violation of TRS policy. TRS employers must not allow employees to reuse or share TRS user accounts.
Which forms are required to get system access?
If you have been newly hired to replace the previous clerk or other person responsible for TRS monthly reporting, it is likely you will need to complete Form 141 (see below) to establish yourself as the online administrator.
If someone else in your school district or organization oversees TRS reporting and you need access as an additional system user, Form 141 is not required. The staff person who is currently designated as the TRS online administrator can add you as an additional user, after you have created your own User ID and password using the Login button, above. You'll give your user ID (not your password) to the online administrator to set you up as an additional user.
What happens after you submit Form 141 or 141A to TRS?
If one or both forms are required, TRS staff will review the information you provided before granting access to the appropriate employer reporting systems. Once access has been granted, you will be able to perform TRS reporting tasks on behalf of your school district or organization.
Account Security and Deactivation
TRS user accounts are deactivated after 90 days of inactivity. If you are granted access to a TRS employer reporting system and you do not log in for 90 days, your user account will be deactivated automatically.
Deactivation occurs separately for each TRS employer reporting system. For example, if you have access to the TRS Insurance Deduction system but you only log in once or twice a year, you will lose access to that system after 90 days of inactivity – even if you log into the TRS Wage and Contribution Reporting System every month. TRS recommends you set a reminder to log in at least quarterly.
- IMPORTANT! Because Additional User accounts are subordinate to the Online Administrator's account, your Online Administrator should log in at least quarterly. If the Online Administrator's account has been deactivated, any authorized Additional User accounts also are deactivated.
To regain access after an automatic account deactivation, call TRS IT team (406.444.9293) during regular business hours.
Positions Reportable to TRS
TRS is required to provide retirement benefits to individuals who work in an educational services capacity with a TRS employer. In general, "TRS employer" includes Montana's public school districts, community colleges, educational cooperatives, CSPDs/RESAs, certain state agencies, and more.
The TRS employer is primarily responsible for identifying all positions reportable to TRS, although TRS members, and especially TRS retirees who return to work for a TRS employer, do have some independent responsibility to ensure their service is properly reported.
Not all TRS-reportable positions can be determined based on their job descriptions. When reportability is unclear, TRS applies a standard set of criteria to determine whether an individual must participate in TRS based on the job duties and functions to be performed.
Read the Fact Sheet linked below for a detailed explanation of this topic.
Fact Sheet: Which Positions are Reportable to TRS?
In 2014, in response to questions from interested parties, TRS examined whether Montana's statewide and regional Comprehensive Systems of Personnel Development (CSPD) and Regional Education Service Agency (RESA) organizations meet the definition of TRS employers.
On October 10, 2014, TRS issued a final determination in this matter, stating that CSPDs and RESAs are TRS employers who must report eligible employees to TRS as active member or working retirees, as appropriate.
A link to the final determination memo is provided below for reference.
Oct. 10, 2014 Final Determination on CSPD and RESA Employer Status
Special Reporting Procedures
Under TRS law, substitute teachers and part-time teachers' aides/paraprofessionals who are not already members of TRS (i.e., those who have no contributions on account with TRS) may elect to postpone (defer) membership until they have worked at least 210 hours in a single fiscal year, the threshold for mandatory participation.
This exception to TRS membership requirements is designed to provide options for new substitutes, aides, and paras whose work hours are unknown and who may never reach the 210-hour threshold.
- IMPORTANT: Only the specific employees described above may elect to defer membership as described.
In 2025, TRS made a major enhancement to the Wage and Contribution Reporting System to track hours for these employees. All K-12 school districts are required to report hours and wages – without contributions – for employees who properly elected to defer membership via TRS Form 106, Member Election for Substitute Teachers and Part-Time Aides/Paras.
Carefully read and follow the Fact Sheet and procedures linked below to ensure accurate reporting.
Fact Sheet: Substitute Teaching and Elective Membership Deferral
Notice: Procedures for Non-Contributing Substitute Teachers and PT Aides/Paras
- Form 106 and related handouts are provided in the Employers section of the Forms and Publications page.
Regular TRS Working Retirees
It is important that TRS employers and retirees understand and comply with all requirements that must be satisfied when a retired member wishes to resume TRS-reportable employment.
For example, there is a required break in service period during which the employee-employer relationship must be completely severed. (The length of the break in service may vary; please see the Fact Sheet linked below.) During the break in service period, a newly retired TRS member generally is prohibited from providing service to a TRS employer in any capacity.
The Fact Sheet linked below explains all requirements, limitations, and exceptions that may apply. Please read it carefully.
Fact Sheet: Working After Retirement
- TRS Form 146 also must be completed by the employer and the working retiree each year. Please see the Forms and Publications page (Employer Forms section) for a link to the form.
Annual Earnings Limitation – Median AFC
TRS retirees may continue to receive their full monthly benefit after resuming TRS-reportable employment, so long as their annual earnings in that position do not exceed the greater of:- 49% of their own Average Final Compensation (AFC) at retirement, or
- 49% of the median AFC of all members who retired in the previous year.
Median AFC: $68,363.24
49% Median AFC: $33,497.99
If annual earnings exceed the limit, the retiree's benefit may be reduced or suspended.
"Emergency Hire" Provisions for Filling Certain Vacancies
19-20-732, MCA provides for a limited exception whereby a Class 2 or Class 3 school district may reemploy an eligible retired TRS member to fill a vacant position on a full-time basis with no reduction or suspension of the retiree's monthly benefit.
19-20-735, MCA, allows a similar exception for the Office of Public Instruction (OPI).
In both cases, TRS imposes a time limit on the reemployment of a retired TRS member. For more information, review the Working After Retirement fact sheet linked above.
Questions about eligibility for these emergency hire provisions should be directed to TRS Executive Director Shawn Graham.
Pursuant to §19-20-307, MCA, any individual working in a position reportable to TRS is presumed to be an employee of the employer.
Unless and until the employer provides a completed TRS Form 148 certifying that Independent Contractor (IC) status has been conclusively determined by a qualified analyst, the employer must report the individual to TRS as an active member or working retiree, not as an IC. (NOTE: This requirement applies even for individuals who previously were reported to TRS as ICs.)
Before an individual can be determined to be an IC and not an employee, it is the employer's responsibility to obtain a comprehensive analysis of worker status performed by an HR professional, attorney, or other person qualified to make such a determination. TRS does not require the employer to include the qualified analyst's written determination with Form 148; however, the employer must certify on Form 148 that such an analysis has been performed.
TRS must review and approve Form 148 before the employer may report the individual to TRS as an IC.
The Fact Sheet linked below explains all requirements for establishing IC status with TRS. Please read it carefully.
Fact Sheet: Establishing Independent Contractor Status
- TRS Form 148 and IRS Publication 963 are available in the Forms and Publications (Employer Forms section) of this website.
The 2025 Legislature passed a bill that expanded the types of extra-duty service reportable to TRS effective July 1, 2025. Be sure you have read and understand the Fact Sheet linked below, which incorporates the legislative changes.
Note about stipend work:- The fact sheet includes a procedure for determining whether stipend work (such as for coaches hired from the community) must be reported to TRS and when it may not be reported to TRS.
Fact Sheet: Calculating and Reporting Extra Duty Service Credit
Audits
TRS employs a full-time auditor who audits wage and contribution reports for up to 36 TRS employers each year. The purpose of a TRS audit is to ensure employees are reported to the correct retirement system and that contributions and service are reported accurately for those working in TRS-reportable positions.
The audit process is designed to be helpful rather than adversarial. Comparing payroll and other records to wage and contribution reports helps ensure both the employer and TRS are complying with governing laws and policies.
If your school district or organization is selected for audit, the auditor will contact you and provide a written list of the data to be collected for the audit and the general process that will be followed.
Reports and Documents Requested and Reviewed During an Audit
- Full worker roster, including names, job titles, and extracurricular assignments
- Complete payroll reports from the employer's payroll software for the specified fiscal year
- Timesheets for hourly employees for the specified fiscal year
- A sampling of I-9 and W-4 information, personnel documents, or membership forms for employees in TRS reportable positions
- A list of all workers being paid as independent contractors
- Other documents or reports as requested by TRS
After receiving and examining these records, the auditor will prepare a preliminary report of findings and will work collaboratively with the employer and TRS staff to gather additional information as needed, answer questions, and correct any reporting errors identified during the audit. This typically involves collecting any contributions due and/or arranging for a refund of overpaid contributions to ensure each affected member's creditable service balance is accurate.
- Questions about the audit process can be directed to Chris Fish, TRS Auditor, at 406.444.6173.