When applying the otherwise excludable rules, there are 3 ways to apply it. (Statutory, Plan Entry, or Beg of Year/6 monts)
Let say in year 1-The ADP & Coverage tests were completed using the Statutory option for applying the OE rule. Plan passes ADP & Coverage.
The plan uses prior year testing.
Year 2: Plan still uses prior year testing, so the average used for ADP is based on Statuory, but if in year 1 the plan had used the plan entry method, the NHCE ADP average would have been higher. Would you need to go back and run coverage in Year 1 using plan entry to be able to use that NHCE ADP average in Year 2?