School Business Insider

Episode: "Secure 2.0 in Action: Preparing for What’s Now Mandatory"

Host: John Brucato
Guests: Michael Linehan (Equitable), Sarah Bryner (Omni TSACG), Phil Hahn (Security Benefit)
Date: November 11, 2025

Overview: Main Theme & Purpose

This follow-up episode revisits the Secure Act 2.0 and its impact on public school retirement plans as districts across the country face new mandatory compliance requirements. John Brucato brings back industry experts Michael Linehan, Sarah Bryner, and Phil Hahn to discuss:

• What’s now required for school districts under Secure 2.0
• District preparedness, practical implementation, and compliance
• The distinction between mandatory and optional plan provisions
• Communication and education strategies for staff
• What’s coming next with Secure Act 3.0

The discussion is designed to provide school business officials clarity on which provisions affect them, help identify where districts must take action, and outline strategies for implementation without overwhelming staff or administrators.

Key Discussion Points & Insights

1. Secure 2.0: Changes from Anticipation to Reality

Timestamps:

• [01:28] - [02:27]

• Two years ago, Secure 2.0 was “on the horizon”; now, mandatory requirements are in effect.

• Major provisions are taking effect in 2025-2026; full implementation approaches in 2026.

• Not all Secure 2.0 provisions impact public school retirement plans (such as 403(b), 457, and 401(a)); many provisions apply only to private-sector ERISA plans.

Quote:
"There were, oh my goodness, over a hundred provisions in this legislation and not all of them affect us in this public education marketplace."
— Michael Linehan [02:27]

2. District Readiness: The Role of Third Party Administrators (TPAs)

Timestamps:

• [06:25] - [08:46]

• District preparedness is closely tied to the quality of the relationship with their TPA.

• Districts with a strong TPA partner have confidence and clarity in implementation.

• For districts without a TPA, now is a critical time to reconsider securing one.

• Some changes (e.g., mandatory Roth contribution via payroll) are a “heavy lift” and require operational updates.

Quote:
"Districts that are feeling very comfortable...has been really based on the TPA that they're working with."
— Michael Linehan [06:25]

3. Refresher: What Is Secure Act 2.0 and Why Does It Matter?

Timestamps:

• [10:44] - [12:08]

• Secure Act 2.0 (enacted in 2022) comprises wide-ranging legislative changes intended to make retirement plans more flexible and accessible.

• Key changes include increased distribution options, simplified administration (e.g., self-certification for hardship), and expanded Roth treatment.

• The government is closely monitoring the effectiveness of these plans and is expected to build on these reforms.

Quote:
"It really was a big signal...the [federal government] is watching, is ready to step in and do some things to make sure it’s better and better for everybody."
— Sarah Bryner [10:44]

4. Mandatory Provisions: The “Heavy Hitters”

Timestamps:

• [15:09] - [18:43]

Key Mandatory Provisions:

• RMD Age Increase: Required Minimum Distribution (RMD) age raised from 72 to 73.
• First Day of the Month Rule Eliminated: For 457 plans; salary reduction agreements can become effective immediately, aligning with 403(b).
• Elimination of RMDs for Roth Accounts: Roth 403(b) and 457 participants no longer have to take RMDs.
• Mandatory Roth Catch-Up Contributions: Starting in 2026, employees earning $145,000+ in FICA wages must make age-based catch-up contributions as Roth (after-tax).

Quote:
"The last and final one, which is the star of, I think it might be more of a nightmare or a thriller, is the mandatory Roth Age catch up contributions, which says in 2026 is when this must be implemented."
— Sarah Bryner [17:17]

5. Operational Impact & Implementation Details

Timestamps:

• [19:33] - [24:30]

• Districts must ensure Roth contribution capabilities in their payroll systems.

• Even if only one or two employees meet the $145,000 threshold, the plan must accommodate mandatory Roth catch-ups.

• Plan document amendments for Secure 2.0 provisions aren’t required until 2029 for governmental plans, but the changes themselves must be implemented according to their effective dates.

• The IRS has provided a “good faith compliance pass” for 2026, recognizing it as an administrative period.

Quotes:
"If you want to implement Roth that Roth feature you have to update your plan document. But the plan document amendments that are associated with Secure 2.0 are not required to be updated until 2029."
— Sarah Bryner [23:32]

6. Optional Provisions: Flexibility and Local Decision-Making

Timestamps:

• [29:48] - [36:51]

• Optional (“opt-in”) features allow earlier fund access in cases like FEMA disasters, personal emergencies, domestic abuse, and employer Roth contributions.

• Most districts, guided by their TPAs, adopt these features to provide maximum benefit to employees — but some proceed cautiously to avoid fraud or administrative complexity.

• Decision-making on optional features is often localized and may reflect employee demand, geographic risk factors (e.g., for disaster withdrawals), and administrative feasibility.

Quote:
"I always would say to a district: walk before you run. There’s some wonderful provisions that have been offered but there still needs...We got to be very careful."
— Michael Linehan [33:04]

7. Communicating Changes and Educating Staff

Timestamps:

• [32:18] - [41:34]

• Effective communication is essential, especially since most employees do not reference plan documents.

• Emphasis should be on updating procedures, policies, and direct communications (email, meetings, PD days).

• Use provider and TPA expertise for group presentations, FAQs, and tailored employee education.

• Segmenting communication — distinguishing between employees affected by new rules (e.g., earners over $145,000) and those who are not — simplifies messaging.

Quotes:
"There’s a lot of information already in the marketplace right now. TPAs are communicating. We are. All I know, Phil, is we are. There’s not any one of our clients that haven't been aware of the fact that we’ve got Secure 2.0 coming."
— Michael Linehan [39:44]

8. Looking Forward: Secure Act 3.0 and Pending Reforms

Timestamps:

• [42:34] - [47:36]

• "Rothification" will continue; Roth features will expand, and additional requirements are expected.

• Growing pressure on state pension plans is driving increased reliance on voluntary supplemental plans.

• Secure 3.0 may also intersect with Social Security reforms.

• Flexibility and ease of access, as well as participant self-certification, are expected to remain legislative focal points.

Quote:
"I think my cat's already in the bag. Roth. It's going to continue to be Roth. Rothification that will continue...so I think as we look here is...the state pension plans are not going to be able to give you the 100% that you're looking for. So it really is going to be on these voluntary supplemental plans."
— Sarah Bryner [42:56]

Notable Quotes & Memorable Moments

• On TPA Relationships:
  "Districts that are feeling very comfortable...has been really based on the TPA that they're working with."
  — Michael Linehan [06:25]

• On Increased Flexibility:
  "It really was a big signal...the [federal government] is watching, is ready to step in and do some things to make sure it’s better and better for everybody."
  — Sarah Bryner [10:44]

• On Plan Amendments:
  "But the plan document amendments that are associated with Secure 2.0 are not required to be updated until 2029."
  — Sarah Bryner [23:32]

• On Flavor of Legislation:
  "I always would say to a district: walk before you run."
  — Michael Linehan [33:04]

• On Secure 3.0 and the Future:
  "It's, it's the constant of change. Right. We are seeing from year to year with the, with the enhanced ability to bring these benefits so that we recognize teachers...deserve the retirement..."
  — Michael Linehan [44:54]

Segment Highlights with Timestamps

| Topic | Time | |-----------------------------------------------------------------|--------------| | Setting the stage: Where are we now with Secure 2.0 | [01:28] | | District readiness and the role of TPAs | [06:25] | | Secure 2.0 refresher | [10:44] | | Mandatory provisions rundown | [15:09] | | Plan amendment timing and IRS guidance | [23:22] | | Optional provisions—local and TPA decision-making | [29:48] | | Communicating with employees | [38:01] | | Anticipating Secure 3.0 & Social Security reform | [42:34] |

Conclusion

The transition from Secure 2.0’s introduction to mandatory action has been significant for school districts. Preparation, clear understanding of applicable provisions, and strong partnerships with TPAs are key to compliance. While plan document changes aren’t required until 2029, operational and communication changes must already be in place to meet mandatory rules.

Looking ahead, further “Rothification” and possible Social Security reforms will likely keep school retirement planning in flux, reinforcing the need for proactive learning and adaptable systems.

Final takeaway: "As long as you have a solid TPA, you should be in great shape." — John Brucato [47:49]