bully for you.
I do like the fact you have a unique situation, no one really knows for sure how to handle, but it's the software that needs fixing to handle it. Though I'm surprised the client want the numbers this week
usually they want the numbers 2 weeks ago, even though they didn't give you the info until this week!
No, they don't.
The rule is that any disparity that exists should not be one that unfairly discourages a member of the terminated group from continued participation. Think two-tiered fee structure where terminated folks are charged 10 times what others are charged. Not good. But if they are charged their fair share of administrative expenses while actives have the administrative expenses paid by the plan, that is fine.
In this case unless the two options are markedly different for some reason I can't see it being an issue.