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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    ERISA

Date & Time
  • event Date

    Tuesday, February 6, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$347.00
CLE
ALL

This CLE webinar will provide employee benefits counsel and plan sponsors guidance on new IRS regulations for 401(k) eligibility for long-term part-time (LTPT) employees. The panel will discuss key provisions of the new IRS regulations and the impact on eligibility and participation requirements, determining whether an employee is an LTPT employee, vesting requirements for LTPT employees, and other notable items.

Faculty

Lori L. Shannon
Miscellaneous

Ms. Shannon counsels private and public companies and tax-exempt entities on the design and implementation of employee benefit and executive compensation plans and arrangements. She advises clients in regard to tax-qualified retirement plans, 403(b) plans, health and welfare benefit plans, nonqualified deferred compensation plans and equity-based incentive plans. Ms. Shannon assists clients, many in the professional services arena, with the design and drafting of executive and physician employment agreements, as well as severance, retention and change in control agreements.

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Nicole D. Bogard
Partner
Barnes & Thornburg

Ms. Bogard practices in the firm's Employee Benefits & Executive Compensation Department where she collaborates with executives, in-house counsel and human resource professionals at publicly traded and private companies to design compliant total rewards programs that facilitate business objectives. She has considerable experience with counseling clients on the Affordable Care Act, HIPAA privacy and security rules, wellness programs, self-funded health plans, COBRA administration, and nondiscrimination rules. Ms. Bogard also represents clients with matters before the IRS and the DOL.

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Description

On Nov. 27, 2023, the IRS issued proposed regulations regarding eligibility requirements for LTPT employees under Section 401(k) of the IRC. These regulations provide guidance on determining who are LTPTs, requirements for plan participation, and other critical items that employee benefits counsel must understand in advising plan sponsors and administrators.

Prior to these regulations, plan sponsors were allowed to exclude part-time employees from 401(k) plan participation if such employees had not reached the age of 21 or completed at least 1,000 hours of service within a 12-month period. However, since the enactment of the SECURE Act and SECURE 2.0, such requirements have been reduced along with other special rules for participation for LTPT employees.

The new regulations contain certain items critical to LTPT employees, such as eligibility requirements regardless of the employer's classification of the employee, the impact on those considered to be former LTPT employees, methods for crediting service, vesting, and other key items.

Listen as our panel discusses key provisions of the new IRS regulations and the impact on eligibility and participation requirements, determining whether an employee is an LTPT employee, vesting requirements for LTPT employees, and other notable items.

Outline

  1. Recent IRS guidance for LTPT employees in defined contribution plans
  2. Impact of SECURE Act and SECURE 2.0
  3. Determining who are LTPT employees
  4. LTPT employee eligibility for plan participation
    1. When they can begin participating
    2. Counting hours
    3. Acceptable methods for crediting service
    4. Vesting
  5. Contributions
  6. Next steps for plan sponsors and administrators

Benefits

The panel will discuss these and other key issues:

  • Determining who are LTPT employees under recent IRS guidance
  • What happens when a LTPT employee who is eligible to participate in CODA later ceases to be a LTPT?
  • When can LTPT employees begin participating in the plan?
  • What are acceptable methods for crediting service?
  • Best practices and next steps for plan sponsors and administrators