Since January, employees age 50 and older who earned more than $150,000 in FICA wages from their plan-sponsoring employer during 2025 have been barred from making pre-tax catch-up contributions. IRS Notice 2025-67 set that threshold, raising it from the statutory $145,000 base figure — a distinction worth noting, because many summaries still quote the unindexed number.
For teachers, nurses, hospital staff, and church employees in 403(b) plans, the final regulations left one door open. It is narrow, it is easy to miss, and a second test built into the statute closes it for a surprising share of the people who would benefit.
Why the 15-Year Catch-Up Escapes the Roth Mandate
Section 402(g)(7) lets employees with 15 years of service at a public school system, hospital, home health service agency, health and welfare service agency, or church defer up to $3,000 above the standard elective deferral limit. This is a separate provision from the familiar age-50 catch-up, and the ordering rule is what matters.
Under Treasury regulation section 1.403(b)-4(c)(3)(iv), deferrals above the standard limit are treated first as special 403(b) catch-up contributions and only then as age-50 catch-up contributions. The preamble to the final catch-up regulations draws the conclusion explicitly: "the special section 403(b) catch-up contributions are not subject to section 414(v), including the requirement under section 414(v)(7) that certain catch-up contributions be designated Roth contributions."
Treasury and the IRS also confirmed in that same preamble that participants reaching age 60 through 63 may make the special 403(b) contributions in addition to the enhanced catch-up. For 2026, a 61-year-old hospital employee who qualifies could defer $24,500 standard, plus $3,000 as a pre-tax 15-year catch-up, plus $11,250 as a Roth catch-up — $38,750 total, with $27,500 of it pre-tax rather than the $24,500 ceiling that applies to everyone else above the wage threshold.
The Arithmetic Test That Usually Blocks It
The $3,000 is not automatic. The permitted amount is the least of three figures: $3,000; $15,000 reduced by special catch-up amounts used in prior years; or $5,000 multiplied by years of service, minus every elective deferral the employee has ever made to the plan.
That third prong is the trap, and it cuts against precisely the group the Roth mandate targets. An employee with 20 years of service gets a $100,000 ceiling — reduced by all prior deferrals. Someone who has consistently deferred large amounts to clear a $150,000 salary has almost certainly blown through that figure, leaving a permitted special catch-up of zero. The provision works best for long-tenured employees who saved modestly for years and only recently crossed the wage threshold through promotion or added clinical hours.
None of these dollar figures are indexed for inflation, either. The $3,000, $15,000, and $5,000 amounts are fixed in the statute.
Practical Takeaways
Confirm your plan offers it. The 15-year catch-up is optional. Many 403(b) sponsors never adopted it, and no amount of eligibility helps if the plan document is silent.
Ask for the cumulative deferral figure, not just your tenure. Fifteen years of service is only the entry ticket. Request your lifetime elective deferral total from your recordkeeper and run the $5,000-times-years calculation before counting on anything.
Do not assume 457(b) works the same way. Governmental 457(b) plans have their own final-three-years catch-up, but the preamble describes a different interaction in which part of the catch-up can still be forced into Roth treatment. Treat it as a separate question.
Mind the timeline. The statutory Roth catch-up requirement applies now, but the detailed regulations under section 1.414(v)-2 generally apply to contributions in taxable years beginning after December 31, 2026. For 2026, plans operate under a reasonable, good-faith standard — so coordination errors are worth catching before the stricter year begins.
Sources: IRS Notice 2025-67; Treasury Decision 10033, Catch-Up Contributions final regulations (90 FR 44528); IRS Retirement Topics — 403(b) Contribution Limits; 26 U.S.C. 402(g)(7)