SECURE 2.0, enacted in 2022, reshaped retirement plan administration for businesses. With new requirements around eligibility, catch-up contributions, and auto-enrollment, the law is designed to make saving easier for employees, but it adds a new layer of complexity for organizations looking to stay compliant.
Fortunately, platforms like Infor HCM can simplify the process. Sue Pokorny and Ariane Silva of RPI Consultants provide a practical walkthrough of how to set up your Infor HCM system to meet SECURE 2.0 requirements.
Session attendees will learn how to configure:
- Long-term part-time eligibility for 401(k) plans
- Roth after-tax catch-up contributions for reporting requirements
- Catch-up eligibility for age-based contribution limits
- Mandatory auto-enrollment
Sue and Ariane will reveal leading practices on testing and validating Infor HCM, so you can be confident your system is not just compliant but also running smoothly.
If you’re looking to empower your employees and ensure compliance with the latest rules and regulations surrounding retirement plan administration, this session is for you.
Transcript
Sue Pokorny
Thank you for joining us for our Simplifying the SECURE Act 2.0 webinar. My name is Sue Pokorny and I’ve been a consultant here at RPI for going on five years now. Prior to RPI, I spent 20 years working with the Infor Lawson products and have both practical and implementation experience across the full suite of HR Talent. Joining me today is my colleague Ariane Silva, who will introduce herself and walk us through the agenda.
Ariane Silva
Hello everyone, my name is Ariane Silva. I’m a senior consultant here with RPI. I’ve been with RPI for about 10 years now — time flies when you’re having fun. I work a lot with GHR benefit implementations, and I know that many of our clients are now getting ready and researching the provisions coming in under the SECURE Act 2.0 — trying to figure out what system changes might be needed, what Infor has already made available, and how to test that out. We’re hoping today’s presentation can help you navigate through those changes. One of our goals is to show you what is already available in terms of system functionality. We’re also hoping to answer some of your questions — we may not get to all of them, but we’ll certainly try.
Quick disclaimer before we dive in: we do not offer legal advice. We recommend referring to your legal department to make sure you understand the regulation and which provisions apply to your organization. The presentation today reflects our understanding of system functionality and the changes that will be needed. We are monitoring all of the new enhancements that Infor is releasing and will continue testing this new functionality. We’ll make sure you’re always up to date and informed on upgrades and enhancements.
Let’s talk about our agenda. We want to start with a brief overview of what SECURE Act 2.0 is, then dive into some of the provisions: determining eligibility for part-time resources, the over-wage-limit requirement, the super catch-up, and auto-enrollment. After walking through those provisions, we’ll switch over to Infor and give you a quick demo of what functionality is available, what you can start testing right now, and how to test it. Then we’ll close with a look at upcoming enhancements — we know there’s a CU update in October and we’re expecting system enhancements with that release. Without further ado, let me hand it over to Sue to get us started.
Sue Pokorny
The SECURE Act 2.0 from 2022 builds on the original SECURE Act from 2019. The intent was to strengthen the retirement readiness of individuals throughout the country — aimed at expanding employees’ access to retirement plans and increasing their individual savings for retirement. As a result of SECURE 2.0, there are several updates needed in our HR and payroll systems to ensure compliance, specifically around benefits, deductions, and contribution limits. Today we’ll cover the regulation changes for 2026 and the system updates Infor is planning to deliver in October that will support the new legal requirements. Our focus for this presentation is on multi-tenant HR Talent. For any S3 folks on the call, feel free to stay on, but today’s demo will cover HR Talent. Ariane, I’ll let you kick off the first requirement.
Ariane Silva
Thank you, Sue. Let’s talk about the part-time eligibility provision. Under the SECURE Act, employers offering 401(k) plans were required to offer those plans to part-time resources who had worked more than 500 hours per year over three consecutive years. What changes with SECURE Act 2.0 is that period is shortened to two consecutive years. In terms of system impact, we need to make sure we are tracking employee hours worked and can identify which employees have worked those hours over that specific period, so that those employees can be offered retirement plans if they haven’t been already.
We’ll cover that piece in a moment and show what system functionality is available to support this provision.
Sue Pokorny
Let’s talk catch-ups — specifically the mandatory requirement for Roth contributions. Starting January 1st, employees age 50 and over who made $145,000 or more in the prior year will be required to make their catch-up contributions on a Roth basis. To do this, the system will need to identify who those high earners are, monitor their pre-tax contributions, and once they hit the pre-tax limit, convert their deduction to a Roth deduction. One thing to keep in mind here for new hires: it is the employee’s responsibility to ensure they’re setting up their contributions in accordance with the new regulations. You won’t know what their earnings were with their previous employer, so they’ll need to make sure they’re setting up any catch-up contributions correctly.
To make things a little more complicated, the act is also introducing a new catch-up limit — referred to as the super catch-up — which applies to employees ages 60 to 63. This group is allowed to contribute a higher catch-up amount, and just like with the regular catch-up for employees 50 and over, if they earned more than $145,000 last year, this deduction must be a Roth contribution. Once the employee hits age 64, they return to the original catch-up rules used by the 50 to 59 age group.
To help manage the catch-up rules, we’ve created a matrix to help identify when a Roth contribution is required. In the table you can see the age groups and the contribution limits for calendar year 2025. For employees up to age 50, they can contribute up to $23,500 — pre-tax, after-tax, their choice. For the 50 to 59 age group, they have the same $23,500 limit plus a catch-up contribution: if they’re under the $145,000 threshold, the catch-up can be pre-tax or after-tax; if they’re over $145,000, the catch-up must be Roth. For the 60 to 63 super catch-up group, they have the $23,500 pre-tax limit and are allowed $11,250 for their catch-up. If they’re under $145,000 in prior-year wages, they can do pre-tax or after-tax; if they’re over, it must be Roth. And once they hit age 64, they return to the same rules as the 50 to 59 group — pre-tax or post-tax if under $145,000, Roth if over.
Additionally, SECURE 2.0 is introducing mandatory auto-enrollment with automatic contribution increases for any new plans offered by employers. The key here is any new plans — defined as any 401(k) or 403(b) plan established after December 29, 2022. For these plans, automatic enrollment at 3% took effect on January 1, 2025, and the first automatic increase for those individuals is happening as of January 1, 2026. Two things to keep in mind: employees do have the option to opt out entirely or change the amount of their contribution, in which case the auto-escalation would not apply. And employers who have been established for less than three years or have fewer than 10 employees are exempt from this requirement.
Ariane, let’s jump into the system.
Ariane Silva
Thank you, Sue. We’re going to start with a review of the new flags that have been created to support SECURE Act 2.0 and show you how to access that information. Under Benefits, you also have access to the employee profile from all the different roles. If you go to Resources and select an employee — I’ll use our testing resource — and double-click on the record, you’ll see the Benefits tab has been updated with a SECURE Act section. This section currently has three checkboxes. The first is Eligible, which will flag resources that are eligible for retirement based on their hours worked. The Over Wage Limit checkbox should flag every resource that had over $145,000 in wages from last year. And Catch-Up Eligible should flag all resources age 50 and over. There are some enhancements coming to those checkboxes that we’ll talk about later.
I’d like to walk through the job now so you can see how those flags get updated. You can always run an IDS upload if you don’t have the information and need to check those flags manually, but Infor has created a job under Maintenance Processes called Secure Act Eligibility that helps you identify resources falling under each of the different provisions. If you select the job, you’re brought to the Secure Act screen, which has two tabs. The Create Report function is under the Proposed tab. If you’re already familiar with benefits processing, you’ll see this is very similar to other reports in Benefits. Once you click Create Report, you can select the benefit group — I’d recommend creating a group with all of your active resources that need to be evaluated.
As of right now, the job needs to run for all the different provisions, so the term and eligibility fields all need to be populated — the asterisks indicate required fields. The FTE threshold: I’d add something like 0.1 here — we don’t want to enter 1.0 because we want to make sure it’s evaluating part-time resources as well. Pay class: you’d select the pay class related to employee hours worked, which you can coordinate with payroll. Infor has made these parameters user-defined so that if any of the provisions change, you can simply come in and update the values.
As of right now, the requirement for part-time eligibility evaluation is 500 hours, so we’d plug in 500 here. The job was initially created for three consecutive years, but we now only need to evaluate two years. Since I’m running the job in 2025, I’d enter January 1, 2024 through December 31, 2024 for year one, and January 1, 2023 through December 31, 2023 for year two. The third year range can be left blank for now.
For the Determine Over Age Limit field — also user-defined — the provision establishes that resources with wages over $145,000 in the previous year will be subject to the over-wage-limit provisions, so we’d enter that amount here. The wage source: our understanding is that Infor will be releasing enhancements to this list. As of right now, we’re not able to see HRT wages — the wages coming from GHR payroll — but Infor has enhancements coming that will bring in that functionality. For now, if you want to test this, I’d recommend querying your hours worked, loading it to one of those business classes, and using that to validate the report.
If I select Wage History and Taxable Wages, for example, the system will ask what year to evaluate. I’d enter 2024 here. If you were running this in 2026, you’d enter 2025. Then the Determine Catch-Up Eligible field tells the system which resources are turning 50 this year and should be evaluated for catch-up eligibility. Once you populate those parameters, you submit the job. I’m not going to submit it right now because I already ran it.
The results show up on the Proposed tab. You’ll see a list of all employees in your benefit group. The system evaluates them and indicates which fields need to change — those are marked with an exclamation point. For example, looking at employee number three: their current flags show Eligible as Yes, Over Wage Limit as Yes, and Catch-Up Eligible as Yes. What this job is proposing is to change the Over Wage Limit to No based on the hours worked it evaluated. If you want to update those records, you can either update the selected employee only — in this case just employee number three — or update all employees. After updating, if you open the resource record, you’ll see the changes reflected in those checkboxes. That’s what the Secure Act Eligibility job does: it identifies those resources and proposes the appropriate flag changes.
Now let’s cover the changes Infor made to support auto-enrollment. Sue touched on that provision earlier. There are some changes to the contribution table, and I want to walk through those and show which jobs we can leverage to see auto-enrollment happening in the system. Let me switch back to Infor.
We’re under Plans now. I want to look at our 401(k) plan. If your plan is being introduced now, this provision is for new plans — you’d want to set this plan as Always Default for this process to work. Once you select Always Default, the system allows you to select a percentage for resources that are newly eligible and should be auto-enrolled. It will enroll them at that initial percentage. That additional information is under your Contributions tab. If you double-click on the Contributions tab, you’ll see a section for SECURE Act Percent Increment Rules. There are two sections to populate: the default rule — what the initial default contribution percentage should be for employees becoming eligible — and the automatic increment: for this plan, what is the maximum contribution percent?
I want to show you a small gotcha here. We still don’t know if Infor’s upcoming updates will change this, but when you’re creating your contribution table, those fields are available. However, once you populate a calculation, you can no longer change it. Keep that in mind if you’re testing and building this contribution for the first time.
Another thing I want to show you related to auto-enrollment is an existing job: Mass Enroll Default Plans. This job can be used to auto-enroll resources in the plan if you have the Always Default setup enabled. You can select the plan and then select the SECURE Act Auto Enrollment option, which tells the system which plans to evaluate for the SECURE Act. When the job runs, it creates the enrollment for the resource. You can verify this under Benefit Resources — if you search for an employee enrolled in that plan, you’ll see the SECURE Act Auto-Enrollment flag set on their record. If at any point a resource should no longer be considered, you’ll want to remove that flag.
Each year, the auto-enrollment will kick in again. Most likely you’ll need to create new contribution tables. Under Maintenance Processes, the Benefit Plan Update job is responsible for updating all resources enrolled in a plan to the next contribution tier. This job ensures the auto-increase is happening correctly.
We’ve been closely following and testing Infor’s releases, and there are some enhancements coming in the October CU. We haven’t tested this functionality yet, but we’ll be testing each one once it’s available. The first enhancement is an additional wage source on the Secure Act Eligibility job for clients using multi-tenant HRT payroll. The second is the implementation of a super catch-up identifier — since resources between ages 60 and 63 move into a super catch-up and then back to a normal catch-up, Infor is introducing a new checkbox to help identify those resources. The last enhancement is allowing different tiers for total contribution limits, which will be especially helpful given the now-different catch-up requirements.
Let me switch back to the system and look at the contribution limits. This is under the Payroll module — go to Payroll Administration and set up your deductions listing, which will have the Defined Contribution Limits and Defined Contribution Rules. The Defined Contribution Limits screen is where you can add the max compensation and deferral amounts. Infor will be bringing enhancements to this screen to account for the different age-based maximum contribution requirements.
Another area I’m sure will generate a lot of questions is the rollover. When resources hit $145,000 in prior-year earnings and reach a catch-up contribution, the provision requires that catch-up contribution be made on a Roth basis. We’ve been testing some of the functionality Infor has suggested — linked deductions, limit deduction codes, and similar approaches — but we’re not yet in a position to show you complete testing results. We’re hoping the October enhancements will help us finalize that testing as well. I’ll hand it back over to Sue to talk through some key considerations around the SECURE Act 2.0 changes.
Sue Pokorny
Yes. So — important considerations and next steps. Things to consider: do you offer 401(k), 403(b), or 457 plans to your employees? If yes, we recommend you review the new requirements and determine how they’ll impact your workforce. Keep in mind that changes are not only needed on your benefit plans, but also with your deduction structure and with BSI. We highly recommend that your benefits and payroll teams test these changes together to ensure you’re handling contributions and limits correctly.
When auto-enrolling and auto-escalating employee contributions, keep in mind that employees can change their contribution amounts — and once they change their election, the auto-escalation no longer applies.
We also recommend updating your benefits guide to include the regulations regarding Roth catch-up contributions for high earners. This will alert new employees who are eligible for those catch-ups to the new requirements.
Finally, as Ariane mentioned, we’re actively testing Infor’s recommendations and running into some of the same testing challenges as many of you. Infor is planning to include SECURE 2.0 updates with the October release, so more is coming. In the meantime, start your testing now so that you’re prepared to continue testing once the release comes out.
Here are a couple of helpful Knowledge Base articles from Infor. And as always, we’re here to help. If you have any questions or need assistance implementing these changes, please email us at questions@rpic.com. Thank you all for attending, and have a great day.
