Q1 Plan Sponsor Checklist

Year-End Data Request: Plan sponsors should submit plan year-end data for 2023 Non-Discrimination Testing and the 2023 Form 5500 to their plan service provider (this is usually submitted between January and the beginning of February, however, plan sponsors should check in with their service provider to confirm deadline dates). It is important to submit data timely as refunds may need to be processed for HCEs by the IRS deadline on March 15th in the event of a non-discrimination testing failure. If refunds are processed after the IRS deadline a 10% penalty will apply. Additionally, if your plan qualifies as a large plan, please contact your Independent Qualified Public Accountant (IQPA) to initiate the audit process required for the plan Form 5500. Typically a plan covering more than 100 participants at the beginning of the plan year is considered a large plan and will require a plan audit. However, if the plan meets the conditions of the 80 to 120 Participant Rule, it may file as a small plan. Under this rule, if the number of participants covered under the plan as of the beginning of the plan year is between 80 and 120, and a small plan annual report was filed for the prior year, the plan administrator may elect to file as a small plan.

Flexible Discretionary Matching Contribution Notice: Plans that provide a Flexible Discretionary Matching Contribution are required to provide a notice to participants no later than 60 days after the final discretionary matching contribution is provided for the plan year.

Long-Term Part-Time Employees (LTPT): Beginning with entry dates in 2024, 401(k) plan administrators must permit Long-Term Part-Time Employees to make at least elective deferrals. Prior to SECURE 1.0, the law permitted administrators to exclude (on a service basis) from participation employees who did not complete at least 1,000 hours of service during a one-year (12-month) period (e.g., part-time, seasonal and temporary employees). SECURE 1.0 amended the law to require administrators of 401(k) plans with service eligibility requirements to permit employees who completed at least 500 hours of service during each of three consecutive one-year (12-month) periods (beginning on or after January 1, 2021) (“LTPT Employees”) at least to make elective deferrals.  For example, an employee who completed at least 500 hours of service in 2021, 2022 and 2023 must be permitted to make elective 401(k) deferrals as of the employee’s entry date in 2024. Administrators can continue to exclude LTPT Employees from employer contributions. Plans need not credit pre-2021 service for vesting purposes.

Administrators also should be aware that SECURE 2.0 further has amended this requirement. Beginning with entry dates in 2025, administrators of both 401(k) and 403(b) plans (with service eligibility requirements) must permit employees at least to make elective deferrals who have completed at least 500 hours of service during each of two consecutive one-year (12-month) periods. For example, an employee who completes at least 500 hours of service in 2023 and 2024 must be permitted to make elective deferrals to a 403(b) plan as of the employee’s entry date in 2025. USICG encourages administrators to review plan eligibility provisions and to review service tracking practices to ensure compliance with the SECURE 1.0 and 2.0 Acts.

Business Planning: Consider any changes to business and staffing needs that may affect the company retirement plan and inform your USICG consultant so they can assist you in evaluating your retirement plan needs (mergers/acquisitions, etc.). Please refer to the following Mergers & Acquisitions guide for additional information pertaining to mergers & acquisitions and retirement plans. >Click here

Tax Saver's Credit: Educate employees that fall within specific salary ranges on their qualification for an IRS tax savers credit (please refer to Q1 Employee Communications resources).

Plan Review: Work with USI and your plan recordkeeper to review 2023 year-end plan statistics and discuss goals for the retirement plan in 2024.

Education Strategy: Collaborate with USI and your plan recordkeeper to devise an employee education plan and communication calendar for 2024.

Q1 Plan Sponsor Literature & Education

Fiduciary Governance: The purpose of this communication is to provide some general principles regarding the plan governance structure for retirement plans. >Click here

Retirement Plan Resources: Periodic newsletter and legislative updates designed to highlight various employee benefit matters relating to Defined Contribution and Defined Benefit plans. >Click here

Market and Legal Updates: >Click here

Q1 Employee Communications

Tax Saver's Credit: an employee education literature piece regarding the IRS Tax Savers Credit that employees may qualify for if they fall within a certain salary range. >Click here for 2023 Credit | >Click here for 2024 Credit

>A Better Way to Use Your Tax Refund: How to use your tax refund to help improve long-term financial well-being. 

>Understanding Your 401(k) Plan: This flyer provides information on the importance of reviewing retirement accounts periodically to evaluate whether appropriate investments and savings are being considered.

In addition to the employee communications noted above, please feel free to check out our Learning Station Website to access additional employee education materials and webinar announcements.

Q2 Plan Sponsor Checklist

2022 IRS Form 5500 & IRS Form 5558: Ensure all information for 2023 Form 5500 & IRS Form 8955-SSA preparation has been submitted in to your plan service provider. Plan sponsors with large plans (100 employees or more) should schedule a plan audit. If your plan requires a plan audit or you require more time to submit the Form 5500 & Form 8955-SSA, you should ensure that a Form 5558 will be filed by July 31, 2024 to enable you an extension to submit your final Form 5500 & Form 8955-SSA by October 15, 2024.

Non-Discrimination Testing Review: Review 2023 Non-Discrimination Testing Results with your USI Consultant and discuss whether mid-year testing or plan design changes like Automatic Enrollment or Safe Harbor should be considered. 

Schedule Employee Education Meetings: Discuss employee education meeting strategy/topics and best timing for scheduling meetings.

Q2 Plan Sponsor Literature & Education

Retirement Plan Resources: Periodic newsletter and legislative updates designed to highlight various employee benefit matters relating to Defined Contribution and Defined Benefit plans. >Click here

Market and Legal Updates: >Click here

Plan Sponsor Literature: Attention to Detail and Regulatory Changes Can Help Minimize Retirement Plan Errors - This literature piece notes the steps plan sponsors should take to help limit plan errors, correct plan deficiencies and mitigate audit risk. >Click here

Q2 Employee Communications

Beneficiary Designations - This education piece helps employees to understand the importance of having and maintaining beneficiary designations. >Click here

Investing Diversification - This education piece focuses on the importance of diversification. >Click here

In addition to the employee communications noted above, please feel free to check out our Learning Station Website to access additional employee education materials and webinar announcements.

Q3 Plan Sponsor Checklist

2022 IRS Form 5500 & IRS Form 8955-SSA: Plan sponsors are required to finalize their plan 2023 Form 5500 & IRS Form 8955-SSA and submit it into the IRS by July 31, 2024. If more time is required for a plan audit, plan sponsors should ensure that their plan provider will submit Form 5558 into the IRS by July 31, 2024 to ensure an extension will be granted. Once the extension has been filed, the new deadline date for submitting the 2023 Form 5500 & Form 8955-SSA will be October 15, 2024.

SMM: The Summary of Material Modifications (SMM) is a plan-language description of the material changes to the plan or SPD (Summary Plan Description). Plan Administrators must furnish the SMM or an updated SPD to each participant and beneficiary no later than 210 days after the end of the plan year in which the plan amendment is adopted (by July 28, 2024 for calendar year plans). Please consult with your provider or USI Consultant to determine whether an SMM or SPD needs to be distributed to participants for plan amendments that became effective in 2023.

Auto-Enrollment & Safe Harbor Plan Design Changes: Plan sponsors who wish to adopt automatic enrollment provisions or a safe harbor plan, effective January 1, 2025, should finalize discussions towards the beginning of October with USICG and their service provider to ensure sufficient time for amendments and annual notice distribution requirements. Please refer to the following Comparison of Safe Harbor and Auto Enrollment Options Chart to learn more information pertaining to these plan design options: >Click here

Q3 Plan Sponsor Literature & Education

Retirement Plan Resources: Periodic newsletter and legislative updates designed to highlight various employee benefit matters relating to Defined Contribution and Defined Benefit plans. >Click here

Market and Legal Updates: >Click here

Plan Sponsor Literature: Plan Sponsors Can Do More to Improve Retirement Readiness - This literature piece goes over the steps plan sponsors can take to help improve retirement readiness for their employees. >Click here

Q3 Employee Communications

Roth - If your 401(k) plan offers a Roth option you may want to provide this Q&A education piece to your employees to assist them in understanding how Roth contributions work. >Click here

Budget - This literature piece discusses the importance of maintaining a budget to meet financial goals. >Click here

Loans - This education piece goes over what employees should consider prior to taking a 401(k) loan. >Click here

Save More - Encourages employees to save more in their retirement account to help achieve retirement planning goals. >Click here

In addition to the employee communications noted above, please feel free to check out our Learning Station Website to access additional employee education materials and webinar announcements.

Q4 Plan Sponsor Checklist

2022 IRS Form 5500 & IRS Form 8955-SSA Extension Deadline: Plan sponsors who were granted an extension to file the 2023 IRS Form 5500 & IRS Form 8955-SSA by filing a Form 5558 are now required to submit the final 2023 Form 5500 & Form 8955-SSA by October 15, 2024 (including auditor's report for large plans). Typically a plan covering more than 100 participants at the beginning of the plan year is considered a large plan and will require a plan audit. However, if the plan meets the conditions of the 80 to 120 Participant Rule, it may file as a small plan. Under this rule, if the number of participants covered under the plan as of the beginning of the plan year is between 80 and 120, and a small plan annual report was filed for the prior year, the plan administrator may elect to file as a small plan.

Annual Notices: Plan sponsors that have adopted plans with automatic enrollment or safe harbor provisions should contact their service provider to ensure annual notices are distributed 30-90 days prior to the beginning of the plan year. In addition, the participant notices noted below must be distributed by the following deadline dates:

Summary Annual Report (SAR) - The SAR for 2023 must be distributed to all participants by September 30, 2024 unless an extension was granted to file the 2023 Form 5500. If an extension was granted, the 2023 SAR will need to be distributed to all participants by December 15, 2024.

Annual 404(a)(5) Participant-Level Fee Disclosure - This disclosure is required to be distributed no later than 14 months from the last time it was distributed to participants (In 2014, the DOL granted a 2 month grace period after the 12 month required timeframe for distributing these disclosures).

Qualified Default Investment Alternative Notice (QDIA) - Plans containing a default fund that qualifies as a QDIA, are required to provide an annual notice 30-90 days prior to the beginning of the plan year in order for the default fund to be recognized as a QDIA by the DOL. The DOL will provide additional liability protection to plan sponsors as it relates to the plan default fund if it is designated as a QDIA.

403(b) Universal Availability Notice: An annual notice is required to be provided to all employees in 403(b) plans, except for Church plans.

Flexible Discretionary Matching Contribution Notice: Plans that provide a Flexible Discretionary Matching Contribution are required to provide a notice to participants no later than 60 days after the final discretionary matching contribution is provided for the plan year.

2024 Discretionary Amendments: Amendments for plan design changes that became effective in 2024 need to be formally adopted by December 31, 2024. Plan sponsors should ensure they maintain executed copies of all plan amendments and restatements.

Mandatory Cash-outs, Forfeiture Accounts & ERISA Budgets: Plan sponsors should work with their providers to coordinate mandatory cash outs of small plan balances prior to year end. In addition, plan sponsors should review balances for their forfeiture account and ERISA Budget with their provider and USI Consultant to ensure they are utilized appropriately.

Q4 Plan Sponsor Literature & Education

Retirement Plan Resources: Periodic newsletter and legislative updates designed to highlight various employee benefit matters relating to Defined Contribution and Defined Benefit plans. >Click here

Market and Legal Updates: >Click here

Plan Sponsor Literature: Fiduciary Fundamentals for ERISA Plan Sponsors - This literature piece goes over the four basic fiduciary duties under ERISA that plan sponsors should adhere to. >Click here

404(c) Compliance: This communication provides information pertaining to 404(c) guidance for plan sponsors >Click here

Q4 Employee Communications

Understanding Tax Benefits: This education piece helps employees understand the importance of saving in their retirement plan to take advantage of tax deferred compounding. >Click here

November Budget: Budgeting tips to consider when planning for holiday shopping. >Click here

December Budget: Checklist to aid employees in meeting retirement and financial goals in the New Year. >Click here

In addition to the employee communications noted above, please feel free to check out our Learning Station Website to access additional employee education materials and webinar announcements.