Life goes fast. Feels about 10 years ago that I started as an ERISA attorney in practice and that was almost 25 years ago. It’s 2023 and before you know it, it will be 2024.
It is time for you to realize that the longtime, part-time exclusion will become law, where employees with 500 hours of service within 3 consecutive years of employment will be eligible to defer in a 401(k) plan. The problem is when you deal with split provisions, it will lead to administrative mistakes. In addition, if you forget to get these employees involved in the plan, you may have missed deferral opportunities and corrective contributions.
So I think it makes sense to identify who will be eligible right off the bat in 2024. Doesn’t hurt to prepare ahead of time.