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Agreed.

Suppose an employer had a 3% safe harbor nonelective 401(k) plan in 2020 with pro-rata profit sharing. In 2021 they adopt a scond plan, a new PS plan, retroactively to 1-1-2020 and it has each person in their own rate group. Can this new plan offset the minimum gateway by the 3% safe harbor nonelective provided to those same participants in the 401(k) plan?

Whatever you do, act fast and consider what the impact is on death benefits if there are any family member she cares about.

I wonder if you need a POA (power of attorney) for them to talk to you. Another resource might be this "assistance" group from the American Academy of Actuaries. https://www.actuary.org/content/pension-assistance-list-pal. (I've participated myself.)

If the plan is aggregated then the contribution counts towards the overall gateway.

Its semantics but it appears based on the information you provided that this is a "transfer" within the plan assets and not a "distribution" of plan assets. Therefore no 1099-R should have been generated. That being said, I had a client some years ago with a similar situation and the 1099-R reflected the name of the Plan. The broker and client tried to get the investment firm to fix it but they refused. There was never any fallout or followup by the IRS in our case.