Under the SECURE Act and the SECURE 2.0 Act, employers must provide so-called long-term, part-time employees – i.e., those who complete at least 500 hours of service in three consecutive years (reduced to two years in 2025) and are at least 21 years old – the opportunity to make elective deferrals under their 401(k) plans and, beginning in 2025, their 403(b) plans.
Most employers with impacted plans reviewed their eligibility-tracking processes some time ago in anticipation of the initial effective date of the new rule. However, with that new rule now effective – and last-minute guidance now available – it is important for employers to review those processes to determine if further changes are needed or desired.