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The form can be filed on a cash basis or a modified accrual basis (where the only accrual is for the contribution). It would be a very unusual 1 person plan that used pure accrual. Whatever you first use you should continue to use.

Bill, precious few! Flyboy, to the best of my knowledge the instructions don't specifically mention an exception to the general rules that forces one into modified accrual for the purpose of determining whether a form is required to be filed. I explain the alternatives and let the client decide whether to file or not. That is, whether to adopt modified accrual or cash basis reporting.

Kevin, interesting... The short plan year regs I think only say "you must be safe harbor fort he next year" and do not specify that it must be the same safe harbor? That is very very interesting!

That is really odd. I think it is valid because it is not based on service for the Employer. But how do you find out who is a college student? How could you possibly enforce it? That would be my concern. What if they drop out and forget to tell you? What if they were not in college before, but subsequently enroll, and forget to tell you (or intentionally withhold the information?). The plan should not include criteria that is not based on information it can verify. That is just plain silly.

You have to have some very strange circumstances for a PW plan to fail a4. Convince me.