SECURE 2.0, 401(k), and Roth: What It Actually Means for CMiC Payroll Configuration
The SECURE 2.0 Act didn't just change retirement plan rules on paper. It changed what your payroll system has to actually do. Automatic enrollment, Roth catch-up requirements for higher earners, long-term part-time eligibility - these aren't policy decisions your HR team makes once and files away. They're ongoing payroll configuration, and getting them wrong doesn't fail loudly. It shows up as a compliance gap someone finds later, usually at the worst possible time to find it.
The Provisions That Actually Touch Payroll Configuration
Automatic enrollment for new 401(k) plans - eligible employees have to be automatically enrolled at a default deferral rate, which has to be built into payroll deduction setup, not just written into plan documents.
Roth catch-up requirements for higher-compensated employees - catch-up contributions above a compensation threshold have to be processed as Roth, which means payroll needs to correctly identify who's affected and route their catch-up deductions accordingly.
Long-term part-time employee eligibility - part-time employees who meet reduced service-hour thresholds have to be tracked for 401(k) eligibility in a way many payroll setups weren't originally built to handle.
Increased catch-up limits for a specific age band of employees - this has to be reflected accurately in deduction limit configuration, not left as a manual adjustment.
Why This Is Harder in CMiC Than It Looks on Paper
SECURE 2.0 compliance requires layered calculation benefits and HR rules on top of deduction setup you likely already have. A Roth catch-up rule that only applies above a compensation threshold, or eligibility that only kicks in past a service-hour threshold, should be reflected in configuration and tracking - not handled as a manual exception someone has to remember.
Where Automation Actually Belongs in This
Every one of these provisions has a manual version and an automated one. Someone can track part-time employee hours toward eligibility in a spreadsheet -or it can be tracked in CMiC. Someone can manually flag which employees cross the compensation threshold for Roth catch-up each year -- or that identification and routing can happen automatically inside payroll processing. The manual version works until someone forgets a step during a busy pay cycle. The automated version reduces the risk of missed compliance. We build SECURE 2.0 compliance into CMiC as automated configuration wherever the platform allows it, specifically so it isn't riding on a person's memory.
This Is a Compliance Decision Before It's a Configuration Task
CMiC configuration is how a decision gets implemented - it isn't where the decision gets made. Which SECURE 2.0 provisions apply to your plan and which employees fall into which thresholds should be confirmed with your plan administrator, recordkeeper, or ERISA counsel. Once that's determined, we make sure your CMiC configuration matches it and automates it wherever possible.
Where We Help
We translate an already-determined plan design into correctly configured, maximally automated CMiC payroll deductions - eligibility tracking, catch-up routing, deduction limits - so what your plan document says and what payroll actually does match exactly, without relying on manual follow-through. Whatever your plan requires under SECURE 2.0, we can help you implement it correctly and automate it in CMiC where possible. If you're not confident your current configuration reflects it, let's talk.
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