"[T]he IRS and Treasury Department also issued as a part of the notice important transition relief indicating they anticipate that the final regulations ... will provide that a State or local retirement system that covers employees of a public charter school that meets the requirements of the guidance under consideration ... for periods starting on and after the effective date of the final regulations will not fail to be a governmental plan ... even if the plan covered those employees for periods before the effective date of the final regulations when the public charter school did not meet the requirements of the guidance ... In other words, charter schools will have until the effective date of the final regulations to make any changes needed to meet the requirements of the final regulations[.]"