Haley Dow
Subscribe to Haley Dow's PostsHaley M. Dow focuses her practice on employee benefits and executive compensation matters. Read Haley M. Dow's full bio.
New Rules Make Tracking Long-Term, Part-Time Employee Service a Full-Time Job
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Feb 15, 2024
Posted In Employee Benefits, Retirement Plans
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,...
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This Is Not a Test! IRS Confirms Long-Term, Part-Time Employees Excludible From Certain Nondiscrimination Testing
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Feb 13, 2024
Posted In Employee Benefits, Retirement Plans
Under the SECURE Act and the SECURE 2.0 Act, employers must provide long-term, part-time employees the opportunity to make elective deferrals under their 401(k) plans and, beginning in 2025, their 403(b) plans. When this occurs, certain special rules apply to such employees that impact whether they must be included in annual nondiscrimination testing or receive...
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When It Comes to Vesting, IRS Says Once a Long-Term, Part-Time Employee, Always a Long-Term, Part-Time Employee
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Feb 8, 2024
Posted In Employee Benefits, Retirement Plans
Under the SECURE Act and the SECURE 2.0 Act, employers must provide long-term, part-time employees – i.e., employees 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,...
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IRS Confirms Same Hours-Counting Rules Still Add Up for Long-Term, Part-Time Employees
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Feb 6, 2024
Posted In Employee Benefits, Retirement Plans
Following the SECURE Act and the SECURE 2.0 Act, employers must now offer employees who work at least 500 hours within three (reduced to two beginning January 1, 2025) consecutive 12-month periods an opportunity to make elective deferrals to their 401(k) plans and, beginning in 2025, their 403(b) plans. This new long-term, part-time employee rule...
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Under Long-Term, Part-Time Employee Rules, Some Things Change, and Some Things Stay the Same
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Feb 2, 2024
Posted In Employee Benefits, Retirement Plans
Together, the SECURE Act and the SECURE 2.0 Act require employers to offer employees who work at least 500 hours within three (reduced to two beginning January 1, 2025) consecutive 12-month periods an opportunity to make elective deferrals to their 401(k) and, beginning in 2025, their 403(b) plans. In doing so, the new rule raises...
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A Long-Term, Part-Time Employee or a Former Long-Term, Part-Time Employee, That Is the Question
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Jan 30, 2024
Posted In Employee Benefits, Retirement Plans
Under the SECURE Act and SECURE 2.0 Act, employers must provide long-term, part-time employees the opportunity to make elective deferrals under their 401(k) plans and, beginning in 2025, their 403(b) plans. Under the new rules, long-term, part-time employees include those employees who complete at least 500 hours of service in three consecutive years (reduced to...
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A Long-Term, Part-Time Employee or Not a Long-Term, Part-Time Employee, That Is the Question
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Jan 25, 2024
Posted In Employee Benefits, Retirement Plans
Under the SECURE Act and the SECURE 2.0 Act, employers must provide long-term, part-time employees the opportunity to make elective deferrals under their 401(k) plans and, beginning in 2025, their 403(b) plans. This new rule is fraught with complexity and has generated numerous questions about how the requirements apply. But in talking about the new...
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IRS Says Keep Those Class Exclusions Classy Under Long-Term, Part-Time Employee Rules
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Jan 3, 2024
Posted In Employee Benefits, Retirement Plans
Beginning in 2024, employers and plan sponsors will need to implement new minimum eligibility rules, enacted by the SECURE and SECURE 2.0 Acts, that significantly expand eligibility for long-term, part-time employees to participate in employer-sponsored retirement plans. The new rules require that employers who maintain such plans provide employees who work at least 500 hours...
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Last-Minute Guidance Leaves Little Time for Long-Term, Part-Time Employee Changes
By Sarah L. Engle, Brian Tiemann, Haley Dow and Scott Kenkel on Dec 20, 2023
Posted In Employee Benefits, Retirement Plans
The Internal Revenue Service (IRS) recently issued new guidance clarifying key aspects of the broadened retirement plan eligibility rule for long-term, part-time employees under the SECURE 2.0 Act. However, with the new rule effective for 401(k) plans beginning January 1, 2024, the guidance leaves employers and plan sponsors very little time to make changes to...
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