The SECURE Act makes a variety of changes affecting qualified retirement plan administration. Some changes were effective upon enactment on December 20, 2019, and others were effective on and after January 1, 2020, affecting  defined benefits plans, 403(b)/457(b) plans, individual retirement accounts, small employers, lifetime income options, RMDs and withdrawals.  However, with the turmoil subsequently caused by the COVID-19 pandemic and passage of the CARES Act, one significant SECURE Act change that is effective on and after January 1, 2021 may have been overlooked.

The SECURE Act requires 401(k) plans that currently exclude part-time employees to expand eligibility for certain long-term part-timers. Part-time employees who meet the plan's minimum age requirement must be permitted to participate in the plan's salary deferral portion if they complete either of the following:

• a one-year-service requirement with the 1,000-hour rule;
• or at least 500 hours of service for three consecutive eligibility computation periods.

While plan sponsors are not required to take into account 12-month periods beginning before January 1, 2021, in determining whether part-time employees satisfy these eligibility requirements, they are required to implement administrative procedures by the beginning of 2021 to determine whether such employees satisfy the new requirements.