Under Long-Term, Part-Time Employee Rules, Some Things Change, and Some Things Stay the Same

By , , and on February 2, 2024

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 numerous questions about how the new service requirement should be tracked. This includes questions about what 12-consecutive month period (often referred to as a “computation period”) employers should use to determine if an employee has completed the requisite service to begin participating in the plan.

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Sarah L. Engle
Sarah Engle focuses her practice on employee benefits matters. She counsels clients regarding a variety of issues, including the design, drafting and operation of tax-qualified pension and profit sharing plans, health and welfare arrangements, and deferred compensation plans. Sarah has experience advising clients on employee benefits design, implementation and transition matters arising in connection with corporate mergers and acquisitions. Read Sarah Engle's full bio.

Brian Tiemann
Brian J. Tiemann counsels public and private companies on a broad range of employee benefit matters, including matters related to pension plans, 401(k) plans and executive and incentive compensation. He advises plan fiduciaries with respect to their fiduciary duties, investment policies and alternative investments. He also advises multinational clients on global employee benefits matters, particularly with respect to global incentive compensation plans. Brian has extensive experience negotiating investment management agreements and service provider agreements. Read Brian Tiemann's full bio.

Haley Dow
Haley M. Dow focuses her practice on employee benefits and executive compensation matters. Read Haley M. Dow's full bio.

Scott Kenkel
Scott Kenkel focuses his practice on employee benefits and executive compensation matters. He has experience assisting clients with regulatory compliance matters related to tax-qualified retirement plans and executive compensation arrangements. He also regularly works with clients on benefits and compensation issues in connection with corporate transactions. Read Scott Kenkel's full bio.




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