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Plan Eligibility Trends and Increasing Participation

November 18, 2019
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Plan Eligibility Trends and Increasing Participation
By Shawn P. Huxley, CPA, MSA and James Alexander

The main reason employees participate in a benefit plan is to save for retirement.  In a study conducted by Samet & Company, PC, based on employee benefit plans that were audited by Samet, the overall participation rate in 2017 was 38%, while 2016 and 2015 were 36% and 38%, respectively.  These same plans had an average participant balance of $85,174, $77,523, and $73,145 in 2017, 2016 and 2015, respectively.  
This trend mirrors the general performance of the market, with the moderate gain in the market in 2017 contributing to a relatively flat investment balance from 2016 to 2017.  In 2017, the average annual contribution per participant was $5,415, while in 2016 and 2015, the average contribution per participant was $4,775 and $5,358, respectively.  It is interesting to note that the average contribution for plans with under $5 million in assets had an average employee contribution of $2,932, while plans with assets between $5 million and $15 million had average employee contributions of $5,875.  
This highlights the challenge that small employers may experience as they try to get their employees to commit to participating in the plan in a meaningful way.   Of the plans examined, only 29%, 25%, and 19% offered auto-enrollment in 2017, 2016, and 2015, respectively. Enrolling non-highly compensated employees can lead to more favorable results on the plan’s non-discrimination testing.  Improved testing results can also reduce or eliminate amounts that would need to be refunded to highly compensated employees.  
For the 2017 plan year, plans without an automatic enrollment feature had an overall participation rate of 30%, while plans with an automatic enrollment feature had 91% of employees participating.  Many employees tend to take the path of least resistence when making retirement decisions.  If an employee was not initially eligible for enrollment, he or she may continue to bypass participating.  However, if that employee is automatically enrolled, opting out of the plan may be less likely.

In some cases, plans with an automatic enrollment feature may decide to incorporate a step up feature as well.  This feature allows for all participants who were automatically enrolled, to also have their contribution percentage automatically increased annually, up to a defined limit.

Of the plans audited by Samet that feature automatic enrollment, 65% also had a step up feature.  It is worth noting that all of those plans increase participant deferrals automatically by 1% on an annual basis.

For the 2017 plan year, the 401(k) plans examined continued to have a lower average participation rate than the 403(b) plans, with only 36% of eligible employees participating.  The overall participation rate for these 401(k) plans increased in 2017, in part due to the increase in the number of plans that use an automatic enrollment feature, and the drastic effect it can have on participation rates.  
The discrepancy in participation rates between 401(k) plans and 403(b) plans is due in part to the nature of the industry that some of these 401(k) plan sponsors operate in.  In many cases, part time, seasonal, or contracted employees were eligible to participate in these plans, but chose not to, thus lowering the participation rate.
Most plans contained eligibility requirements for participation by employees. Plans typically determined eligibility based on either age, length of service, or both. Of the plans with an age-based eligibility requirement, the majority required that the participant attain the age of 21.  Length of service was also a common requirement for participation in a majority of the plans included in the study.
Increasing Plan Participation
Plan administrators may be noticing a lower than expected participation rate in their employee benefit plan. Increasing plan participation is advantageous not only to employees, but also to the plan sponsor for reasons which include:  
•  Employees that view their employer’s retirement plan as part of their compensation package, along with salary and benefits, are less likely to leave for another company that may offer a higher salary, but no employer match or profit-sharing contribution. As a result, costs associated with employee turnover are diminished.
•  As participation increases, certain fees related to the operation of the plan will decrease per participant.  The added participation will help spread the payment of administrative costs among participants.
•  Highly compensated employees are those who earned over $120,000 in 2017 and 2016 or own greater than 5% of the company.  An increase in participation rate may translate to a higher deferral amount that they are entitled to make based on annual nondiscrimination testing.
There are numerous methods for increasing employee plan participation, which include the following:
Automatic Enrollment – It has been shown that participation rates increase with automatic enrollment. A plan sponsor who automatically enrolls employees when they become eligible will generally notice a higher percentage of participation in the plan.  However, the employee has the freedom to opt out of participation or to defer a different amount before he/she is automatically enrolled.  The employee, depending on the plan, also has the option to withdraw the money without penalty within 90 days of the first automatic deferral.  
Automatic enrollment provisions can generally function in one of two ways. The first method involves automatically enrolling all eligible participants for which no deferral election is on file.  These are usually participants who simply never enrolled in the plan.  The second method involves automatically enrolling all participants who have no deferral election on file, in addition to all participants who have an election on file that is below the automatic enrollment rate.  In both cases, newly eligible participants, are also automatically enrolled in the plan on a going-forward basis at the automatic enrollment rate.  The second method is the more effective one for addressing failed nondiscrimination testing, since a greater number of employees will be brought into the plan.
Matching Contributions – Many employees only contribute to the plan to benefit from the employer match, which is essentially “free money” to the participant.  Increasing the employer’s matching contribution will make contributing to the plan desirable to employees that would otherwise not be compelled to contribute.
Withdrawal Opportunities – Some employees are concerned with financial constraints and feel that plan participation may restrict their ability to meet their current financial needs.  By offering plan loans and hardship withdrawals, these employees should become more comfortable with investing in the plan.
Change Eligibility Requirements and Enrollment Periods – Employee benefit plans that have a length of service requirement might be missing out on potential participants, as the temporary or seasonal nature of their employment precludes them from participating. Workers that have become accustomed to a certain take home pay might be reluctant to take on a 401(k) or 403(b) deduction.  Allowing new employees to enroll immediately should help increase participation.  
Employee Communications – Encouraging employees to participate in the retirement plan should be done when the employee is hired.  Reminding employees about the importance of retirement savings might persuade them to enroll.  This can be achieved through circulating newsletters about the plan, organizing enrollment meetings, and offering enrollment forms to non-participating employees.
Variety of Investment Options – Offering a variety of investment options with competitive investment strategies and fees will entice participants to contribute to the plan.  The plan sponsor should actively monitor the investment mix and assess the investment fees.
Provide a Third-Party Investment Advisor – Many workers are hesitant to invest in a retirement plan because they are unsure how to allocate their funds and how this decision will affect their rate of return.  By providing access to a professional financial advisor, employers can ensure that participants feel more comfortable with their investment allocations.
Educate Employees – Certain classes of employees tend to be cautious about contributing to a retirement plan as they intend to use their whole paycheck for living expenses and may not understand how a retirement plan operates.  Plan sponsors should explain the concept of pre-tax dollars and that a contribution of even 1% of their wages could increase considerably over the span of twenty to forty years due to compound interest.
Implementing all of these techniques may be costly and an administrative burden.  Take into consideration your employee mix and your goals when deciding which of these options will best increase your participation rates.

Shawn P. Huxley, CPA, MSA is a Director at Chestnut Hill, MA CPA firm, Samet & Company PC and can be reached at shawnh@samet-cpa.com or 617-731-1222. James Alexander is a Supervisor at Samet & Company PC and can be reached at 617.731.1222 or jamesa@samet-cpa.com
Plan Eligibility Trends and Increasing Participation
Source: HR.com Articles

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