CP isn’t necessary - the SECURE 2.0 Act expanded retirement coverage for part-time employees (which the neg evidence says part-time employees are disproportionately women).
Boutwell Fay 23, Law firm, “Expanded Coverage For Part-Time Employees Under Secure 2.0,” March 29, 2023. https://www.boutwellfay.com/post/expanded-coverage-for-part-time-employees-under-secure-2-0, HKeef
The SECURE 2.0 Act was signed into law in December 2022, and it expands the requirement to cover long-term part-time (LTPT) workers in 401(k) plans and ERISA-covered 403(b) plans to start in 2025.
Background – SECURE Act and Earlier
ERISA and Internal Revenue Code §410(a) restrict the maximum age and service requirements for eligibility to make 401(k) employee elective deferrals to age 21 and a year of service respectively. A plan may require up to 1,000 hours in a 12-month period to attain a year of service. Adoption of the maximum one year of service requirement can result in the exclusion from the plan of part-time workers who may have long periods of employment.
To address the lack of plan coverage for long-term part-time employees, the SECURE Act, enacted in 2019, provides that effective in 2021 employees who work three consecutive 12-month periods with at least 500 hours of service must be covered by a 401(k) plan’s elective deferral arrangement. For this purpose, hours must be counted starting in 2021, meaning the earliest a long-term part-time employee would enter a plan under these provisions would be January 1, 2024. A plan can still impose an age requirement (up to age 21). No matching or other employer contributions need to be made, and these LTPT employees can be excluded from non-discrimination testing such as ADP/ACP, 410(b) and top heavy testing.