Does universal availability apply to Roth 401(k) options?

[Guest darkdarcy]

Does anyone know if an employer that has both union and non-union* employees is obligated to offer Roth 401(k) contribution options to both groups? It can be beneficial to hang on to new benefit options like this until the next collective bargaining cycle rather than offer it up to everyone regardless of union status, but I'm unclear as to whether this is okay in this case. I know the universal availability business was eventually amended with respect to catch-up contributions due to concerns about the administration of such requirements to collectively bargained groups, but I haven't seen anything either way for the Roth 401(k) stuff.

*using union and non-union in place of reference to collective bargaining agreements' existence/non-existence

[g8r]

Universal availability doesn't apply to Roth K. While the proposed regs are silent on this, the statutory language doesn't impose this requirement.