Letter requests two-year delay of the Roth catch-up requirement to enable public sector plans and employers to comply, prevent participant loss of ability to make contributions for 2024; requests provision of transition relief as expeditiously as possible

Lexington, KY, June 22, 2023—The National Association of Government Defined Contribution Administrators (NAGDCA) today announced that it has joined an action letter produced by the American Benefits Council requesting legislation to delay the effective date of Section 603 of SECURE 2.0. NAGDCA is the premier professional association for plan administrators and services providers of government-sponsored defined contribution retirement plans.

The letter states that “although some plans may be able to comply (including some signatories to this letter) at great cost and burden, a vast number of plans and employers will not be able to comply with the new requirement, effective for 2024, that workers who earned over $145,000 in the preceding year from the current employer must make their catch-up contributions on a Roth basis. For many of these plans, unless this requirement is delayed very quickly (i.e., this summer), their only means of compliance will be to eliminate all catch-up contributions for 2024. If a delay is not announced until, for example, the fourth quarter, it will be too late to prevent this adverse result, since compliance systems need to be designed well before the effective date.”

The letter then provides explanation for the need to delay the requirement. “These challenges exist in part because systems do not exist – and certainly cannot be built in 2023 – to instantly coordinate payroll systems (which determine who earned over $145,000 in the prior year) with plan recordkeeper systems that must ensure compliance with the new catch-up rule. These circumstances pose a long list of other obstacles including, for many plans, the challenges of adding a Roth feature and communicating that feature to participants, as well as special challenges for state and local governments and collectively bargained plans.

Specifically, the letter requests that “To ensure that this change in the law does not unintentionally result in the elimination of catch-up contributions, the undersigned are seeking a two-year delay of the Roth catch-up requirement described in Section 603 of SECURE 2.0, plus (1) any time necessary to give state and local governments the opportunity to consider and enact needed legislation and (2) any additional time to avoid requiring changes during the term of a collective bargaining agreement or other applicable binding agreements.”

Given the proximity of the 2024 effective date, the signatories are asking Congress to provide transition relief as expeditiously as possible.

The letter is addressed to House Ways & Means Committee Chair Jason Smith (R-Missouri) and Ranking Member Richard E. Neal (D-Massachusetts), and Senate Finance Committee Chair Ron Wyden (D-Oregon) and Ranking Member Mike Crapo (R-Idaho), and cc’ed to United States Secretary of the Treasury Janet Yellen.

The full letter may be viewed here.

NAGDCA is encouraging its members to add their organization to the more than 100 entities that have joined the letter. The deadline for participation is Monday, June 26.

NAGDCA provides education, information, and training in all aspects of public plan administration to support members in creating plans that enable secure retirement outcomes for their participants. National Retirement Security Week, originally conceived by NAGDCA to encourage retirement saving among government workers, has grown into National Retirement Security Month, a national effort to inspire American employees to save adequately for a secure retirement that is observed throughout the retirement industry during the month of October. It has received bipartisan Senate resolution since its conception in 2006. To learn more about NAGDCA, visit

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