Sponsors have until the last day of the 2022 plan year (2024 for governmental plans) to adopt plan amendments associated with these provisions. For participants who may have taken an RMD before the CARES Act took effect, the IRS has clarified that all 2020 RMDs — even those received as early as January 1 — may be rolled back into a qualified account by August 31, 2020. Moreover, such a rollover would not be subject to the one-rollover-per-year rule.