UNITED STATES RAILROAD RETIREMENT BOARD - 1 

Program 

Letter 

United States 

Railroad Retirement Board 

Bureau of the Actuary and Research 

Quality Reporting Service Center 

Email: QRSC@rrb.gov 

 Phone: (312) 751-4992 

 Fax: (312) 751-7123 

Letter No. 2024-02 

 

 Date: February 9, 2024 

CONTACT: Vincent Lui Phone: (708) 943-8680

 Bureau of the Actuary and Research Email: BA15@rrb.gov 

 

TO: Certification Contact Officials 

SUBJECT: Form BA-15, Report of Stock Options and Other Payments For 2023 

Please share this information with the appropriate members of your staff who file service 

and compensation reporting forms for employees of your organization. 

This program letter is to inform you about Form BA-15, Report of Stock Options and Other 

Payments for 2023. The Form and instructions remain consistent with the reporting of last year. 

The report is due February 29, 2024. 

Employers submitting Form BA-15 should follow the steps listed below under the section “How to 

Report”. Whether you submit by File Transfer Protocol (FTP) or secure E-mail, please confirm 

that your report is properly formatted. The BA-15 record layout is available under “Appendices” 

in the “Rail Employer Reporting Instructions” (RERI) or “Labor Employer Reporting Instructions 

(LERI)” pages (see under the section “Useful Links”, links to “Electronic File Format”). 

Reasons for Collecting Options Data 

The information on stock options and other non-taxable payments is essential in determining the 

payroll tax amounts involved in the financial interchange with the Social Security Administration 

and the Centers for Medicare & Medicaid Services. In addition, cash flow projections of the social 

security equivalent benefit account and railroad retirement account and cost estimates made for 

proposed amendments to laws administered by the Railroad Retirement Board (RRB) are 

dependent upon input developed from the information collected. 

How to Report 

The instructions and formats for submitting the stock options and other non-taxable payments 

report are contained in the Part V Chapter 8 of the RERI or LERI pages (see under the section 

“Useful Links”, links to “Form BA-15 Filing Instructions”). Reports sent by secure E-mail or using 

File Transfer Protocol (FTP) are required to be accompanied by Form G-440, Report 

Specifications Sheet. Filing instructions for Form G-440 can be found here: Chapter 02: Filing 

Instructions for Form G-440, Report Specifications Sheet | RRB.Gov. 
UNITED STATES RAILROAD RETIREMENT BOARD - 2 

The employer is required by section 209.2 of the RRB's Regulations to report and submit a Form 

BA-15, Report of Stock Options and Other Payments for all employees that received non-qualified 

stock options (NQSOs) and/or other non-taxable payments in 2023. The report includes: 

 Medicare wages, 

 Gross (i.e., unlimited) railroad retirement tax compensation, 

 NQSOs received, and 

 Other non-taxable payments received. 

As a quick data check, Medicare wages should equal the sum of (i) gross railroad retirement tax 

compensation, (ii) NQSOs, and (iii) other non-taxable payments, if any. 

i.e., Medicare Wages = Gross Railroad Compensation + NQSOs + Other Payments, if any 

Upon receipt of data files, we will perform a diagnostic check for data integrity. We will contact 

you by email if we have questions. 

Failure to report or the making of a false or fraudulent report can result in criminal prosecution or 

civil penalties, or both. 

Reports should include initial entries for the reporting year, and up to three years of replacement 

records, if necessary to amend or correct a previous report. Please note the following: 

 NQSOs are not considered taxable compensation under the Railroad Retirement Act, per 

Wisconsin Central Ltd., v. United States (see https://www.rrb.gov/SCOTUS_Decision). 

 Amounts in the BA-15 are not limited to the annual Tier I or Tier II creditable maximum 

amounts for the year. 

 The RRTA gross compensation reported for an employee should not be less than Tier I 

amount reported for the employee for the same year as reported to the RRB on 

Form BA-3, Annual Report of Creditable Compensation. 

Form BA-15 is not required if you have no employees receiving NQSOs and/or other nontaxable payments. Instead, check the appropriate box on the Form G-440, Report 

Specifications Sheet, submitted with your Form BA-3, Annual Report of Creditable 

Compensation. 

Completed BA-15 reports of stock options and other non-taxable payments that are not submitted 

electronically should be mailed to: 

Railroad Retirement Board 

Bureau of the Actuary and Research 

844 N. Rush Street* 

Chicago, IL 60611-1275 

Estimated Completion Time 

We estimate this form will take an average of 300 minutes per positive response to complete for 

a given calendar year and an average of 15 minutes per negative response to 

complete. Responses include the time needed for reviewing the instructions, getting the 

applicable data, and reviewing the completed form. Federal agencies may not conduct or sponsor, 

and respondents are not required to respond to, a collection of information unless it displays a 
UNITED STATES RAILROAD RETIREMENT BOARD - 3 

valid OMB number. If you wish, send any comments regarding the accuracy of our estimate or 

any other aspect of this form, including suggestions for reducing the completion time, to the 

Associate Chief Information Officer for Policy and Compliance, Railroad Retirement Board, 844 

North Rush Street, Chicago, IL 60611-1275. 

Useful Links 

Excel Template of Form BA-15 

 Report of Stock Options and Other Payments (12-21) | RRB.Gov

Form BA-15 Filing Instructions 

 RERI link: Chapter 08: Filing Instructions for Form BA-15, Report of Stock Options and 

Other Payments | RRB.Gov

 LERI link: Chapter 08: Filing Instructions for Form BA-15, Report of Stock Options and 

Other Payments | RRB.Gov

Electronic File Format 

 RERI link: Appendix I: Electronic File Format, Form BA-15, Report of Stock Options and 

Other Payments | RRB.Gov

 LERI link: Appendix I: Electronic File Format, Form BA-15, Report of Stock Options and 

Other Payments | RRB.Gov

RRB Jurisdiction Guide 

 RERI link: Appendix III: Railroad Retirement Board Jurisdiction Guide | RRB.Gov

 LERI link: Appendix II: Railroad Retirement Board Jurisdiction Referral Guide | RRB.Gov

Questions 

If you have any questions about this letter, please e-mail BA15@rrb.gov or call Vincent Lui at 

(708) 943-8680.