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Archives for August 2024

Unlocking the Best Safe Harbor 401(k) Design: Options That Maximize Benefits & Compliance

When it comes to offering a retirement plan that’s both attractive to employees and compliant with IRS regulations, Safe Harbor 401(k) plans are a top choice for many employers. These plans simplify administration by eliminating the need for annual nondiscrimination testing, while also providing employees with valuable contributions that are immediately theirs. But did you know that there are different types of Safe Harbor 401(k) plans to choose from? Each has its unique structure, advantages, and requirements, making it important to understand which one best aligns with your company’s goals. Let's explore the key Safe Harbor plan designs and how they can benefit both you and your employees. 1. Basic Safe Harbor Match  The “Basic Safe Harbor Match” is a straightforward option where you, as the employer, match 100% of the first 3% of employee contributions, plus 50% of the next 2%. This plan encourages employees to save more for retirement while ensuring that your plan remains compliant with IRS rules. All contributions are immediately vested, making it an attractive choice for employees. 2. Enhanced Safe Harbor Match For companies looking to offer a more generous benefit, the “Enhanced Safe Harbor Match” is ideal. It typically involves a 100% match on the first 4% of compensation, although it can be higher. Like the Basic Match, it’s simple to administer, and the immediate vesting of contributions makes it a strong tool for attracting and retaining talent. 3. Nonelective Safe Harbor Contribution  If your goal is to provide a retirement benefit to all eligible employees, regardless of whether they contribute, the “Nonelective Safe Harbor Contribution” is a great option. This plan requires you to contribute at least 3% of compensation to every eligible employee's account, irrespective of their participation in the plan. It’s a robust benefit that demonstrates your commitment to your employees' financial futures. 4. Qualified Automatic Contribution Arrangement (QACA)  The QACA Safe Harbor plan adds an automatic enrollment feature, making it easier to boost participation rates. Employees are automatically enrolled at a contribution rate starting at 3%, which increases by 1% each year until it reaches at least 6% (but not more than 10%). Employer contributions can either follow a match formula—100% on the first 1% and 50% on the next 5%—or be set as a 3% nonelective contribution. Unlike other Safe Harbor designs, QACA allows for a vesting schedule of up to two years, providing some flexibility. Choosing the Right Safe Harbor Plan Selecting the right Safe Harbor 401(k) plan design depends on your company’s specific needs and objectives. Whether you want to encourage employee contributions, ensure broad-based retirement savings, or increase plan participation through automatic enrollment, there’s a Safe Harbor design that fits. By understanding the nuances of each option, you can create a retirement plan that not only meets compliance requirements but also serves as a valuable benefit to your employees.

Scott Higgins | AIF ®, CFP®, CPFA®

Financial Advisor 

Since 2012 at Rose Street, Scott has been responsible for helping the firm’s individual wealth management clients with income strategies for retirement and consulting with employers with their employee retirement plans. In free time, he enjoys golf, biking, skiing, cooking, and traveling. Fun fact, Scott has a hobby of filling growlers with coins! Securities and Investment Advisory Services Offered Through M Holdings Securities, Inc., a Registered Broker/Dealer and Investment Adviser, Member FINRA/SIPC. Rose Street Advisors is independently owned and operated. #6879522.1

Michigan's Minimum Wage &
Paid Medical Leave Laws -
Here We Go Again!

If you’re feeling a bit of whiplash regarding the minimum wage and paid medical leave news in Michigan, you’re in good company. Frankly, I’ve lost track of the number of times this has been the topic of the Fun Socks blog.

As a quick refresher, here’s the history:

In 2018, a petition drive was successfully headed to get both a minimum wage proposal and a provision for earned sick time on the ballot for the fall election.  The legislature at that time decided to adopt the ballot proposals, making the ballot initiatives unnecessary.  The initiatives were dropped, and the Michigan Earned Sick Time Act and the minimum wage standard were adopted.  Then, during the lame duck session after the election, the legislature significantly changed the acts by passing the Paid Medical Leave Act and Michigan’s Improved Workforce Opportunity Wage Act of 2018.  Several groups filed a lawsuit challenging the constitutionality of those Acts arguing that the legislature usurped the rights of the people to implement a ballot initiative. 

The initial court ruled that the adopt and amend process was unconstitutional, that decision was overturned by the court of appeals, which was just overturned by Michigan’s Supreme Court.

What does this mean to employers?

The Improved Workforce Opportunity Act and the Paid Medical Leave Act have been eliminated. Both will be replaced by the original ballot initiatives that voters were to consider in 2018 and will take effect February 21, 2025.

What will be the new minimum wage?

We’re not certain yet. The Michigan Supreme Court has tasked the State Treasurer with calculating the inflationary impacts that have occurred since the original 2019 effective date of the ballot initiative.

How much paid time off will we need to offer?

Employers with 10 or more employees will need to offer 72 hours of paid time off per year. It will be accrued at a rate of one hour for every 30 hours worked.

Employers with less than 10 employees still need to offer 72 hours of leave time, but only 40 of those hours need to be paid.

Does this apply to all employees?

Yes. It applies to full time, part time, and temporary employees.

What else?

Employers need to allow employees to take their paid sick time in the smallest increment of time tracked by their timekeeping system.

How should we prepare?

Theres’ some discussion that the legislature will step in with new legislation this fall. I think that is unlikely to happen during the height of a presidential election. For now, HR leaders should use the time before February to review their current policies and compare them to the Michigan Time to Care initial ballot initiative to see what changes they will need to make.

Here's the link: https://legislature.mi.gov/documents/2017-2018/initiative/pdf/MITimeToCareFINAL.pdf

The original ballot initiative for the Improved Workforce Opportunity Wage Act link is: 

https://www.michigan.gov/-/media/Project/Websites/sos/04holland/R3792_Wage.pdf?rev=f9ec92df8ffe443d85d63ee32cd82056

Questions? The HR Consultants at Rose Street Advisors are happy to help! 

Kevin Brozovich

SPHR | CHIEF PEOPLE ADVISOR

Meet Kevin Brozovich, energetic entrepreneur, people-focused team-builder and HR practitioner-turned consultant. For almost 10 years, Kevin was Founder and Chief People Officer of HRM Innovations, a Kalamazoo-based Human Resources consulting firm many would consider the top in the region. After pulling his hair out making daily decisions about running the business (does it matter where the coffee comes from?), Kevin joined forces with the Rose Street Advisors team so he could solely focus on what he loves most: working with clients.

Interested in more?

Let's Talk Proactive HR
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Securities and Investment Advisory Services Offered Through M Holdings Securities, Inc. A Registered Broker/Dealer and Investment Advisor, Member FINRA/SIPC. Rose Street Advisors is independently owned and operated. Please go to www.mfin.com/DisclosureStatement for further details regarding this relationship. Check the background of this Firm and/or investment professional on FINRA's BrokerCheck. For important information related to M Securities, refer to the M Securities' Client Relationship Summary (Form CRS) by navigating to mfin.com/m-securities. Registered Representatives are registered to conduct securities business and licensed to conduct insurance business in limited states. Response to, or contact with, residents of other states will only be made upon compliance with applicable licensing and registration requirements. The information in this website is for U.S. residents only and does not constitute an offer to sell, or a solicitation of an offer to purchase brokerage services to persons outside of the United States. This site is for information purposes and should not be construed as legal or tax advice and is not intended to replace the advice of a qualified attorney, financial or tax advisor or plan provider. CA Insurance License. File #5757992.1

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