NAGDCA Renews Request of Department of Treasury and IRS for Additional Implementation Time for SECURE 2.0 Section 603(b) (1) and (2) Concerning Designated Roth Contributions for Governmental Plans
Letter references proposed regulation issued in January 2025 giving collectively bargained plans additional implementation time; further solicits due haste in publicizing notice of such consideration to allow governmental plans to plan accordingly
FOR IMMEDIATE RELEASE
Lexington, KY, August 20, 2025—The National Association of Government Defined Contribution Administrators (NAGDCA) today announced that it has sent a communication to legal counsel at the U.S. Department of the Treasury and the Internal Revenue Service renewing a March 2023 request for additional implementation time for SECURE 2.0 Section 603(b) (1) and (2) concerning designated Roth contributions for governmental plans. NAGDCA is the premier professional association for plan administrators and services providers of government-sponsored defined contribution retirement plans.
The letter, authored by NAGDCA Executive Director Matt Petersen, cites proposed regulation issued on January 13, 2025 providing collectively bargained plans with additional implementation time and requests that governmental plans receive the same extension. Petersen states, “We submit that governmental plans often face complexities in local law enabling requirements, payroll systems, and administration that most private sector employers do not. Indeed, these challenges can be seen as not dissimilar to those faced by collectively bargained plans.”
He further notes that “although governmental plans have been working diligently to be ready for 2026, because final regulations have not been issued, many are waiting on final regulations to complete their implementation steps.”
Petersen adds that “Traditionally, Congress and your agencies have been considerate enough to provide governmental plans with extended implementation time.” In closing, he writes “If you are able to effectuate our request, we kindly ask that the decision be publicized with all due haste to allow our member governments to make corresponding business decisions.”
The letter was submitted to Philip Lindenmuth, Acting Associate Chief Counsel (EEE), Internal Revenue Service, and Helen Morrison, Deputy Benefits Tax Counsel, Office of Tax Policy, U.S. Department of the Treasury.
A copy of the letter is available here.
ABOUT NAGDCA
NAGDCA is the premier professional association for plan administrators and services providers of government-sponsored defined contribution retirement plans. NAGDCA members include 270 plan sponsors representing 15,000 governments in 49 states. Participants come from every level of state, territorial, and local government, including counties, cities, public safety agencies, school districts, transportation, and utilities. NAGDCA’s members administer governmental deferred compensation and defined contribution plans, including Section 457(b), 401(k), 401(a), and 403(b) plans. To learn more about NAGDCA, visit https://www.nagdca.org/.
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