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  1. John Feldt ERPA CPC QPA
    A plan has immediate eligibility and only allows deferrals. One job type is excluded which consists of NHCEs (normally about 18% of their workforce). The size of that group doubled in 2013, making them become about 36% of the workforce. There is only one HCE. The HCE did not defer last year. Can the plan test the deferral portion of the plan for coverage by using the average benefits percentage test? All of the NHCEs are benefitting at the same rate or higher as the HCE (HCE rate is zero) - this seems too good to be true - what am I missing?
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