Retirement plan rules may not initially seem urgent, but deadlines can quickly change that mindset. When Congress passed the SECURE 2.0 Act, the intent was clear: expand access to retirement plans, encourage higher savings, and modernize how employer plans operate. For physician practices, that intent becomes very real in 2026 as several provisions shift from theory to required compliance.
What I am seeing across physician practices is a growing sense of urgency. Provision implementation that was easy to delay now requires coordination with payroll, updates to plan documents, and clear communication with physicians and staff. Two particular issues are driving most of the uncertainty: the new Roth catch‑up requirement for high earners and the deadline for formal plan amendments. Understanding who is affected, what is required, and where practices are most likely to falter makes the rest of the conversation far more manageable.
What is the SECURE 2.0 Act, and why does it matter to physician practices?
Short answer: SECURE 2.0 is a federal law designed to expand retirement savings and modernize employer retirement plans, with several mandatory provisions that directly affect physician practices beginning in 2026.
From my perspective, this is less about optional enhancements and more about compliance readiness. Practices that wait too long risk payroll errors, participant confusion, and plan document issues that are much more difficult to fix after the fact.
For more information, view the U.S. Department of Labor’s overview.
Who is considered a “high earner” under SECURE 2.0?
A high earner is an employee who:
- Is age 50 or older, and
- Had FICA wages over $150,000 in the prior year, as reported in Box 3 of the Form W‑2
This determination is made annually and applies only to catch‑up contributions. I always recommend starting with Box 3 of the prior‑year W‑2 because that single data point determines whether the rule applies. For additional IRS guidance on retirement plan contribution rules, view the IRS’s FAQ page.
What is the Roth catch‑up requirement in 2026?
Beginning January 1, 2026, high earners must make all catch‑up contributions on a Roth, after‑tax basis. Pre‑tax catch‑up contributions are no longer allowed for this group.
I realize scheduling can be challenging, but it is important to start participant education as early as possible. Roth‑only catch‑up contributions can increase current taxable income, and physicians are often surprised by that impact if it is not communicated clearly in advance. The IRS’s comparison of Roth and pre-tax contributions highlights these tax differences.
The IRS provides additional details on catch-up contributions on their website.
What retirement plan actions must employers take by December 31, 2026?
Most retirement plans must adopt formal SECURE 2.0 amendments by December 31, 2026, even if the practice does not choose to implement every optional provision, such as student loan matching or emergency savings accounts.
At a minimum, physician practices should:
- Review and update plan documents
- Coordinate closely with payroll providers
- Communicate changes clearly to physicians and staff
Involving payroll early is one of the best ways to avoid last‑minute compliance issues. Systems must be able to track Roth eligibility, contribution limits, and income thresholds accurately.
Kassouf works closely with Kassouf Retirement Plan Services (KRPS) to help physician practices navigate retirement plan compliance and design. You can learn more about KRPS’s approach to retirement plan consulting and administration on their website.