Finding the Best Fit Between PEPs and State-Run Plans

Experts discuss which small plan solution is most appropriate for different types of businesses.

In recent years, small businesses across the U.S. have gained access to additional retirement plan options, notably pooled employer plans and state-facilitated plans. Oregon kicked off the wave of state-facilitated retirement plans in 2017, and pooled employer plans came on the scene in 2021, all catering to small businesses.  

But which plan is right for a small business starting a new plan? The devil, as always, is in the details.  

Never miss a story — sign up for PLANADVISER newsletters to keep up on the latest retirement plan adviser news.

Factors such as the size of the business, the fees and time managers expect to put into the plan and the goals they have for their participants all play a factor, according to experts. The difference, at the highest level, is that while state plans can be a great way to get people saving, the PEP structure allows for more intricate plan designs and options for participants in the long run—but those bells and whistles, of course, will come at a higher cost.  

State-Facilitated Plans 

According to Georgetown University’s Center for Retirement Research, 19 states either have state-facilitated retirement savings programs in place or have approved programs preparing to launch. Meanwhile, policymakers in many more are considering legislation to implement them; only Alabama and South Dakota have not considered retirement savings legislation since 2012. The programs created by state legislation are primarily aimed at small businesses and companies currently without an in-house retirement plan.  

State-run retirement plans, typically individual retirement accounts, have been touted as a straightforward, no-cost solution for employers looking to offer a retirement plan without shouldering significant administrative responsibilities, says Phil Senderowitz, a managing director at Strategic Retirement Partners. He explains that these plans are appealing for businesses with limited resources, since they generally come without fees.  

“State-run plans don’t cost anything,” he notes, which makes them an economical choice for very small businesses. Additionally, states incentivize participation by keeping employee contributions low, generally at 3% to 5% of earnings. 

However, state-run IRAs lack the flexibility that many employers desire when setting up a retirement plan to reward and retain their employees. According to Senderowitz, the limitations on customization mean that “just allowing [employees] to put their own money into a plan isn’t really a big carrot.” In particular, most state-run plans do not permit employer matches, a feature often used by companies to enhance employee retention and satisfaction. 

Oregon, Illinois and California all progressed from pilot programs to enactment by the end of 2019, but no other states even started pilot programs before late 2021, so state-facilitated savings programs are, as a whole, in their very early stages. 

One side effect commonly seen so far, however, is that business uptake of all retirement savings programs, not only those set up by the states, has increased. Michael Salerno, founder and CEO of the National Professional Planning Group, says while state-facilitated programs might work well for microbusinesses with only a few employees, they are often inadequate for companies with more complex needs. 

“The types of businesses that are going to want to gravitate towards a PEP versus a state-run plan are those that want to have a lesser role in the fiduciary monitoring and running of their plan,” he says. 

The Case for PEPs 

For businesses seeking a more robust retirement plan, PEPs provide several distinct advantages over state-run IRAs. PEPs, established under the Setting Every Community Up for Retirement Enhancement Act of 2019, allow multiple employers to join together in a single retirement plan, pooling administrative resources and costs.  

According to Salerno, PEPs “allow a much greater outsource of administrative function and liability” and provide “additional administrative efficiencies that have not typically been seen in the state-run plans.” 

One of the most significant benefits of PEPs is the potential for a much larger variety of investment choices. Salerno points out that PEPs can also have financial wellness and managed account availability, often missing in state-run plans.  

Holly Verdeyen, a partner in and U.S. defined contribution leader at Mercer, says state mandates raise awareness and demand for pooled employer plans, which strike a better balance for employers aiming to offer their employees a comprehensive and cost-effective retirement solution without overburdening their internal resources.  

“They present a compelling alternative to state-run plans, as pooled employer plans are generally more sophisticated and can potentially reduce investment fees through economies of scale,” says Verdeyen. “Additionally, employerincentives to offer a retirement saving plan have increased with the SECURE 2.0 legislation.” 

Senderowitz highlights another key difference: federal tax credits available to employers who start a PEP. Employers initiating a PEP for the first time may qualify for tax credits that offset startup costs and encourage contributions, including matching contributions. For example, a small business could receive tax credits that allow it to offer up to $1,000 per employee in matching funds over the first two years, a bonus state-run plans generally do not support. 

Cost Comparison 

The cost factor is a crucial consideration for small businesses evaluating retirement plan options. While state-run plans are generally free for employers, PEPs cost. Senderowitz explains that, for some businesses, the expense of managing their own 401(k) plan may be comparable to participating in a PEP due to the pooling of administrative resources and shared costs. In some cases, employers may find they are paying about the same amount for a more versatile plan with additional perks. 

But Senderowitz also stresses that, for many companies, the investment in a PEP translates to less time, effort and responsibility than would be required to manage an independent 401(k). “An employer would likely save in terms of time and energy,” he says, as PEP administrators handle many of the fiduciary responsibilities, reducing liability for the business owner. 

Additionally, while a PEP may cost more initially, Senderowitz points out that tax credits for all defined contribution startup plans can make them effectively free for the first three years, allowing businesses to grow their plans to a point of self-sufficiency before incurring significant costs. 

Advisers’ Role in Optimizing Retirement Plans 

Adviser Salerno underscores the role of knowledgeable consultants in helping businesses make informed choices between a state-run plan and a PEP, based on the goals and needs of their employees.  

“The right adviser is really important at all levels, [from] the employer level all the way through to participating employees,” he says. “That adviser would be intricate, sometimes, in helping each participant create an allocation of risk. I see the best advisers out there not only building a strong plan, but also building a strong peace-of-mind plan.” 

An adviser’s expertise becomes especially valuable in PEPs, because the expanded investment choices may require a tailored approach to meet the needs of different employees. Salerno explains that a proactive adviser can understand a client’s risk tolerance and provide guidance to keep employees on track during market fluctuations.  

“People with access to workplace defined contribution plans typically begin saving for retirement earlier and saving more,” says Verdeyen. “However, one-third of private industry workers in the U.S. lack access to employer-sponsored retirement plans. Both state-run plans and pooled employer plans enhance the accessibility of an affordable retirement plan for small businesses and traditionally under-served communities, thereby potentially promoting increased retirement savings.”  

For businesses with at least 20 employees, PEPs offer a comprehensive, customizable solution for retirement planning that state-run programs may struggle to match. As Senderowitz observes, some employers may prefer to have “a little bit of say in how things are set up,” even if it means taking on a slightly higher cost and administrative burden. 

State-run plans, while cost-effective and accessible, may not align with companies aiming to provide a more substantial benefit for employees, particularly in terms of employer matching. 

Meanwhile, businesses with fewer employees may find the simplicity and no-cost nature of state-run IRAs appealing. Ultimately, the decision hinges on each employer’s needs and goals, and having a trusted adviser to guide them through these options can make all the difference. 

What Is Driving Plan Startups?

Providers credit state mandates and tax incentives, but others point to adviser interest in small plans and more uptake for hourly workers.

By most measures, defined contribution plan growth has boomed over the past decade, even before much of the implementation of the SECURE Act 2.0 of 2022 and the proliferation of state mandates, many of which have not yet launched their programs.

From 2009 to 2022, the U.S. added 144,000 employer-run 401(k)s, ending 2022 with 741,000, according to the most recent tracking from ISS Market Intelligence’s Brightscope, which, like PLANADVISER, is owned by ISS STOXX. While the numbers are still being crunched on Form 5500s from 2023, signs point to the addition of a good chunk more.

Never miss a story — sign up for PLANADVISER newsletters to keep up on the latest retirement plan adviser news.

“We’re expecting another strong year of net new plan addition to the market in 2023,” says Viraaj Kumar, associate director of ISS Market Intelligence, who says new figures should be out in the coming weeks.

 According to ISS MI and the Investment Company Institute, there are still some 6 million businesses in the U.S. without 401(k) plans. Gary Tankersley, head of the core segment of U.S. retirement at John Hancock Retirement, says the plan provider is seeing significant startup growth from such uncovered businesses and expects that to “strengthen” in the next five years.

“As more small and midsized businesses recognize the importance of offering robust retirement plans to attract and retain top talent, we’re expecting the number of startup plans to increase by a notable percentage,” he says. “According to recent industry projections, the volume of new plans could grow by as much as 20% annually, which translates into thousands of new plans each year.”

One tailwind for small business plan growth will come if interest rates continue on their downward trajectory, says Jeff Rosenberger, chief operating officer for plan provider Guideline.

“The interest rate environment plays a role for small businesses in planning for the future and having the capital to add retirement plan benefits,” Rosenberger says, noting that the Federal Reserve’s rate cuts are expected to continue into 2025.

Start Them Up

Payroll and plan provider Paychex found in its own research that more than one-third of small-business employers, 37.6%, offer some type of retirement plan, a jump from 31.7% in 2018, notes Scott Buffington, vice president and general manager of retirement services. That same research found that, since the end of 2019, retirement plan offerings have increased by 9.5% in states where businesses are mandated to have a plan, compared with a 3.4% increase in non-mandated states.

“We are seeing year-over-year growth in new plan starts across the country,” Buffington says.

Paychex itself has booked about 22,000 new plans, either through startup or a transition from another plan, in the last calendar year. Many of the startup plans, Buffington says, are being done through Paychex’s pooled employer plan—which is made up of 90% startups.

Guideline has seen growth, in particular, among its new Starter 401(k) offering made possible from a provision in the SECURE ACT 2.0 of 2022, says COO Rosenberger. The Starter is a simplified plan that, while having lower contribution rates and no company match, is also cheaper to set up and has fewer administrative burdens. Guideline has signed up more than 3,000 since they become available at the beginning of the year.

State mandates, according to Rosenberger’s look at the data, appear to push businesses into exploring private market options, and many arrive at the Starter 401(k). The most Starter 401(k) plans booked by Guideline are in states with mandates, including: California (35% of Guideline’s Starter 401(k) plans), Illinois (6%) and Colorado (6%). In comparison, its traditional 401(k) startup growth tends coincide with larger populations such as California (27%), Texas (7%) and New York (6%).

By the end of 2025, California businesses with fewer than five employees will be mandated to offer a plan. Rosenberger says that will likely drive further plan growth in Starter and solo (also known as individual) 401(k) plans.

Hourly Workers

Another startup plan provider, Human Interest, does not see as much connection to state mandates from the more than 10,000 plan adds it expects to book this year. Rakesh Mahajan, Human Interest’s chief revenue officer, says when he looked at the company’s data on new plan growth, a different trend emerged.

“The big trend for me from an industry perspective … is a disproportionate share of business with hourly workers offering plans—that segment is flying,” he says.

In 2022, about 30% of the people on the Human Interest platform were hourly workers, Rakesh says. Today, it is just shy of 60%, with 70% to 80% of new plans being made up of such workers. The CRO says the shift has come, in part, from a business model that targets all businesses and workers, regardless of expected contribution rates.

“The industry has traditionally focused on assets, as opposed to people,” Mahajan says. “We love all workers, whether white collar or blue collar or hourly—we want to get every truck driver, every retail worker and every coffee shop worker into a plan … not just the salaried people.”

Businesses with these types of workers, he says, are also more open to offering plans now that they can be offered digitally, at low cost and with potential tax advantages.

Jared Porter, co-founder of startup plan provider 401Go, points to yet another trend: advisers getting more engaged with smaller businesses.

He says the state-facilitated plans are a “path of least resistance” for some businesses facing retirement plan mandates. But for the advisers 401Go works through, the mandates are a starting point that allows them to discuss the benefits of a plan and the ease of setup through technology, not to mention the tax incentives via SECURE 2.0.

“It’s a way for advisers to discuss a plan in a way that is not pushy, but is focused on what a plan can do for your business,” Porter says. “Many advisers are hearing that there is this opportunity out there and are shifting their services to meet it.”

Human Element

Porter believes the state programs are just the start of mandating that businesses offer retirement plans, with federal mandates and other programs eventually getting implemented. He says 401Go, working through advisers and payroll providers, will continue to capture that plan growth through an ease and speed of use that legacy recordkeepers are struggling to provide.

“It can take six to eight weeks to get them up and running,” Porter says of those more legacy players. “An adviser doesn’t want to bring that to a client. So we focus on making it easier for that adviser and making sure they get paid as well, so it’s viable for their business. … We like to say we automate everything but the relationship, because you have to have that human connection to make it work.”

Some of those large legacy recordkeepers, including Fidelity Investments, Empower and Principal Financial Group, have built small plan startup programs to try and capture this audience as well.

Mahajan, of Human Interest, believes that, beyond all other factors, worker demand for plan access will drive plan growth. He tells an anecdote of a recent trip to South Carolina, which does not have a state plan mandate, where he noticed two shops looking to hire. One, a cookie shop, was offering free cookies as a benefit. Another, a burger shop, was offering benefits, including a 401(k) plan.

“Everyone loves a free cookie,” Rakesh says. “But there’s an awareness that a 401(k) plan is really what will drive talent attraction and retention.”

«