I'm working on testing, etc. for a controlled group and would appreciate any input on the following controlled group testing/allocation issues:

Company 1 PS Plan - Covers only salaried employees

Company 1 401(k) PS Plan - Covers all employees
Only NHCE's get Non-Elective
Non uniform PS allocation formula. %'s differ per division

Company 2 401(k) PS Plan
100% owned by Company 1
Uniform PS allocation formula within plan

Company 3 401(k) PS Plan
100% owned by Company 1
Uniform PS allocation within plan

Coverage Test - can run per plan using the whole population as denominator. If one plan fails with this method, an Average Benefits test on the whole group of plans would need to be performed.

ADP/ACP Test - can run per plan if Coverage tests pass the same way, otherwise all plans need to be combined for ADP and ACP testing.

Non-Uniform PS allocation for Company 1 - A rate group test, for this plan only, would need to be performed since the allocation rates are not uniform. Since this portion of the plan only benefits NHCE's, wouldn't this automatically pass or would the other plans need to be considered due to controll group issues?

Thanks!
Laurie