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Except that statement, correct? I think it still works just a little more complex. The prior year method is you take the prior NHCE average and use it to measure the current HCE average. How do you know you have the right prior number? You ran the ADP test in the prior year. In that prior year you had to know the HCE average for that year's test. So in that year I compared ADP test to the covearage test. Yes, such person isn't on the next year's 410(b). But even in the prior year method you still run the test the same way as the current year method. You merely split the averages to different years. So I will grant you have a minor point but I think I stand by my idea that to get good averages for any given year that is a valid check. When you use those averages is another question. And yes it seems like every rule has an exception- except this rule. (And Spock always lies for Star Trek geeks)