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  1. We have a plan that is hovering around audit size. At 12/31/12 the plan had 115 participants, so it fell just under the first year audit size for 2013. On 1/1/13 the participant count grew to 160, but the question is, how do we base our count? The plan has no hours or service requirement and entry is on the date of hire. Since this is a health care placement group, we have many employees who work as fill-ins and are hired for a week or so, here and there, during the year. The problem is that if an employee became a participant and terminated during 2011, didn't work at all in 2012, then was hired to fill in for a week in November-2013, the program is counting that participant as a body on 1/1/13. I haven't been able to find any document that discusses how to handle rehires in this situation. Should the beginning of the year participant count be inflated for these "participants," even though they didn't physically get rehired until later in the year?
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