QOTW: LTPT Eligibility SECURE 1&2

Sponsored by MFS Investment Management. 

SECURE 1.0 passed in 2019 included a provision requiring plans to allow LTPT employees (those that work more than 500 hours in a year for three consecutive years) to participate in the plan. SECURE 2.0 reduced that 3-years of consecutive employment to two. This week we asked members if they made changes to the plan to comply with SECURE 1 and if further changes were required for SECURE 2.0.

The majority of plan sponsors stated that part-time employees were already allowed to participate. For those that did need to make changes, most allowed all part-time employees to participate and thus do not have to track hours or make further changes to comply with SECURE 2.0.

Comments follow: 

• 6 month waiting period, same as full-time employees
• All employees are available 1st day on deferrals, need to be with us 1 Year for ER contribution. We also have SCA employees on government contracts as well. We have a 403(b) plan and need to make non voluntary ER contributions to that plan as well if the employee waves the medical. Any suggestions on language to amend the plan?
• All employees are eligible to contribute, with the exception for temporary employees who are not eligible.
• All employees were made eligible but after 3 months of service so no tracking of hours is required
• All of our employees are eligible to participate in our plan immediately upon hire.
• It is a great retention feature for our part-time employee's retirements.
• Our company does not employee anyone on a basis other than Full-Time, so this is N/A
• Our only missing group were our interns. Modified to allow any intern over 21 to contribute to the plan in a non-employer matching capacity. Even allowing our summer interns to participate.
• Our plan has always included part-time employees as eligible participants for all contribution types, however, we do have a 1,000 hour requirement for discretionary profit sharing contributions.
• We already allow PT Regular employees to participate, but not temps on our payroll. Going forward, we will do a three-year lookback for employees classified as temporary.
• We amended our plan to allow all employees, unless excluded by a CBA, the opportunity to participate without matching contributions. The match eligibility requirements did not change.
• We do not match until the previous eligibility criteria  (service and hours) have been met.
• We have no employees that meet the LTPT criteria
• Where this could be a factor for us is do we want to adopt this provision for match eligibility as well. I realize that is not required under 2.0 but it feels like something we should consider.