Long-Term, Part-Time Overview for 2024

November 18, 2024

Starting January 1, 2024, new legislation requires 401(k) plans to allow employees with over 500 hours of service in three consecutive 12-month periods to contribute elective deferrals to the 401(k) plan. Employers must properly track employee hire dates and hours worked to determine eligibility.


For part-time workers, saving for retirement can be a challenge. Many part-time employees are often excluded from 401(k) plans because they often don’t meet the plan’s eligibility requirements. This includes many students, parents and individuals with multiple part-time jobs. However, new legislation that goes into effect on January 1, 2024, is about to change that.


Effective on January 1, 401(k) plans must allow employees who have worked more than 500 hours of service in three consecutive 12-month periods to contribute elective deferrals to the plan. Let’s look at an example.


Example 1

Alex was hired in 2016 as a part-time employee. She has never been able to participate in the company’s 401(k) plan because she didn’t meet the 1000 hours requirement. In 2021, 2022 and 2023, she worked 600 hours per year. She has worked more than 500 hours and completed three consecutive 12–month periods, so she can enter the plan on January 1, 2024.


Example 2

Riley was hired on May 15, 2021 as a part-time employee. He worked 400 hours in 2021, 600 hours in 2022 and 600 hours in 2023. On May 15, 2024, he completed three consecutive 12-month periods; however, he did not work enough hours to be eligible.


Importantly, employers must properly track employee hire dates and hours worked to determine eligibility. Tracking hours is crucial to determining employee eligibility for the plan, including tracking periods starting from January 1, 2021 (since that date going forward determines eligibility). Additionally, employers should be aware of the administrative burden involved in operating their plans and how these changes will affect plan operations under the Long-Term, Part-Time provisions.


According to these rules, employers are not required to make employers contributions to the accounts of LTPT employees, which includes contributions under safe harbor 401(k) plan provisions and top heavy minimums but if employers want, they can. Additionally, employers can choose to exclude employees from nondiscrimination testing related to elective deferrals, employer match and non-elective contributions. See your TPA for more specifics.



2025 and Beyond

For 2025 and with the modifications in SECURE 2.0, the rules change again. An employee only needs two  consecutive 12-month periods with more than 500 hours of service to be eligible to participate in the company’s 401(k) plan.


Example 3

Riley was hired on May 15, 2021 as a part-time employee. He worked 400 hours in 2021, 400 hours in 2022, 600 hours in 2023 and 600 hours in 2024. He has completed two  consecutive 12-month periods with more than 500 hours; he is eligible to participate in the company’s 401(k) plan on the next entry date.



Understanding Plan Eligibility

In summary, the LTPT provisions are a significant change to retirement plan eligibility requirements. While the SECURE 1.0 and 2.0 Acts offer solutions, employers must take action to properly track employee hours and ensure those employees become aware of their eligibility to join the 401(k) plan.


Employers should also evaluate their plan design and consider whether allowing all employees to contribute immediately upon hire would be worthwhile. By working closely with your third party administrator and plan advisor, employers can ensure that they are meeting the requirements of the SECURE 1.0 and 2.0 Acts and offering employees the best possible retirement savings opportunities.




The Gasaway Team


7110 Stadium Drive

Kalamazoo, MI 49009

(269) 324-0080

FAX (269) 324-3834



This presentation is not an offer or a solicitation to buy or sell securities. The material discussed is meant to provide general education information only and it is not to be construed as specific investment, tax or legal advice and does not give investment recommendations.


Certain risks exist with any type of investment and should be considered carefully before making any investment decisions. Keep in mind that current and historical facts may not be indicative of future results.


Additional information, including management fees and expenses, is provided on our Form ADV Part 2 available upon request or at the SEC’s Investment Adviser Public Disclosure website, https://adviserinfo.sec.gov/firm/summary/123807.


This information was developed as a general guide to educate plan sponsors and is not intended as authoritative guidance or tax/legal advice. Each plan has unique requirements, and you should consult your attorney or tax advisor for guidance on your specific situation.


©401(k) Marketing, LLC. All rights reserved. Proprietary and confidential. Do not copy or distribute outside original intent.


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Turbulent times can bring turbulent markets. Many factors cause chaotic swings in the investing world including housing, political elections, and international instability. Despite the financial queasiness this can have, experts consistently have one piece of advice for investors: stay calm and stay the course. Maintaining a long-term investment strategy can help weather the storm of a volatile stock market, whereas reacting irrationally or panicking is the last thing investors should do. History tends to repeat There are a few ways to keep nerves at bay amidst a sea of daunting headlines. First, a historical review shows that market fluctuations are normal. This should serve as a comforting reminder during unstable conditions. According to Fidelity, “...while market downturns may be unsettling, history shows stocks have recovered and delivered long-term gains.” 1 While no one can predict the stock market with absolute certainty, the significant crashes of the last century all saw periods of recovery. For example, after the 2008 market crash, the recovery began almost immediately and achieved an eventual increase of 178% in 5-year returns. 2 These past events reinforce the importance of focusing on long-term financial strategies and goals, not short-term fluctuations. The markets will have bull and bear runs which need time to play out without trying to anticipate short-term trends. However, past performance is no guarantee of future results. Don’t try to catch a falling knife Another potential mistake that investors can make is to stop saving during a market downturn. A popular way to continue savings momentum when nerves are being tested is dollar-cost averaging , or in other words, investing a fixed amount on a regular schedule (e.g., per pay period) that generally results in buying more shares when prices are low and less shares when they are high. Dollar-cost averaging is a stabilizing approach. It can take away some of the fear of timing risk and become less of a system shock than lump sum investing. However, this strategy does not ensure a profit and does not protect against loss in declining markets. You need lemons to make lemonade Downturns are a perfect time to consult with a financial professional or investment advisor to review different strategies and also rebalance your portfolio. It might be time to look at investments 1 Fidelity Viewpoints. “6 Tips to Navigate Volatile Markets.” Fidelity. 6 March 2025. 2 Fidelity Viewpoints. “6 Tips to Navigate Volatile Markets.” Fidelity. 6 March 2025. that have lost value, which can potentially help manage risk exposure and provide an opportunity to reposition the portfolio for recovery. Another possibility is to consider a Roth conversion. If your plan allows for a Roth conversion - moving money from pretax dollars to Roth dollars - then a downturn could help. A conversion in a downturn might result in a lower tax bill for the same number of shares sold, and then the individual can experience the benefits of a Roth account, allowing qualified distributions of future growth to be tax free.3 Market downturns are a part of any investing lifecycle so it’s best to keep a steady hand, consult with your advisor and consider all options so you can weather through this market cycle - and the next one. Information provided herein is not, and should not be regarded as, investment advice or as a recommendation. Investing involves risk, including potential loss of principal. ________________________________________ The Gasaway Team Gasaway Investment Advisors 7110 Stadium Dr., Kalamazoo, MI, 49009 Email: info@gasawayinvestments.com Phone: (269) 324-0080 Website: www.gasawayinvestments.com This information is provided as a general guide to educate plan sponsors. It is not intended as authoritative guidance or tax/legal advice. Each plan has unique requirements, and you should consult your attorney or tax advisor for guidance on your specific situation. ©401(k) Marketing, LLC. All rights reserved. Proprietary and confidential. Do not copy or distribute without permission. ________________________________________ Content is for educational purposes only and should not be construed as a solicitation or offer to sell securities or provide investment, tax, or legal advice. Past performance is not indicative of future results. Investing involves risk, including the potential loss of principal. Always consult with a qualified financial advisor before making any investment decisions. Additional information, including management fees and expenses, is provided on our Form ADV Part 2 available upon request or at the SEC’s Investment Advisor Public Disclosure Site https://adviserinfo.sec.gov/firm/summary/123807 . 3 Fidelity Viewpoints. “6 Tips to Navigate Volatile Markets.” Fidelity. 6 March 2025.
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