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How Are Plan Sponsors Responding to the COVID-19 Pandemic?

Industry Trends and Research

A new survey of plan sponsors finds notable decision gaps between large and small employers in their adoption of the provisions of the CARES Act.

Considering the breadth and potential depth of those retirement plan options now on the table, it is perhaps not surprising that nearly half (47.4%) of the 152 plan sponsor respondents indicated they are still deciding which of the CARES Act provisions to implement, according to the survey by the Plan Sponsor Council of America (PSCA), part of the American Retirement Association. 

Larger plans (plans with 5,000 or more participants) are more likely to have made a determination, with two-thirds already making a decision (66.0%), while fewer than half of smaller plans (plans with fewer than 200 participants) have (48.3%). 

Overall, plan sponsors seem somewhat more open to adopting emergency distribution provisions than increasing loan limits, with nearly half (45.4%) already moving to do so, compared with just a third (32.2%) adopting the new loan provisions. 


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The “snapshot” survey also found that:  

  • COVID-19 distribution: Nearly 70% of large organizations are allowing the distribution of up to 100% of the vested account or $100,000 versus only 20.7% of smaller organizations. 
  • Distribution repayment: Nearly half of respondents (46.7%) have embraced the option to allow repayment of coronavirus-related distributions during the next three years. This is also size-corelated, with 68.1% of large organizations allowing it versus only a third of smaller organizations. 
  • Loan limits: While a third of respondents overall are increasing the plan loan limits in COVID-19 qualified circumstances to $100,000 or 100% of vested account balances, this is true of only 17.2% of small organizations, versus nearly half (46.8%) of large organizations. 
  • Loan payments: More than 60% of large organizations are suspending loan payments due on or before Dec. 31, 2020 and deferring repayment for up to a year, versus only one-in-five (20.7%) of small organizations. 

About one-in-ten (9.2%) aren’t planning to adopt any of these new options, though that is the case at only 2.1% of large organizations. 

While the full impact of the COVID-19 pandemic is not yet known, most plan sponsor respondents—76.5%—are not currently contemplating changes to their current plan designs as a result, including more than 90% of small organizations. However, more than 20% of large organizations indicated they are suspending matching contributions, while only 3.6% of small plans have moved to do so. The report explains that during the financial crisis of 2008-2009, about 20% of companies suspended or reduced plan contributions, and most resumed them relatively quickly.

The full report is available at https://www.psca.org/research/cares_snapshot.

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All comments
Kelly Hutchinson
4 years 3 weeks ago
I'm in rural America and am surprised that we are not seeing more discussion about the fact that under criteria 1 and 2, a participant (or spouse or dependent) MUST HAVE TESTED POSITIVE WITH A CDC APPROVED TEST in order to qualify. To put that in perspective for Kansas, as of this morning's numbers anyway, we have 2,913,000 people in our state. 13,864 have been tested. 1,391 were positive tests. For this reason, I think we'll see more under criteria 3 and/or hardships taken under the federal disaster declaration (which will still require both documentation and the 10% early withdrawal penalty) than we will see under the criteria to have tested positive. Curious if others are pondering this as well.
Nevin Adams
4 years 3 weeks ago
That's a good point - as you note, I suspect that's because the presumption is that far more will be affected by the third condition; someone (3) who experiences adverse financial consequences as a result of quarantine, furlough, layoff, reduced hours, inability to work due to childcare, closing of business, or other factors as determined by the Secretary of the Treasury.