It was determined (after year-end) that a large traditional 401(k) plan had a partial plan termination in 2018. The plan operates on the calendar year. Additional match contributions (plus earnings) were calculated and deposited to the plan in late 2019 as a correction for the 2018 partial termination.
The plan administrator had originally calculated refunds to HCEs for failed ADP/ACP. Now the PA is saying that the plan had to be re-tested for the 2018 plan year after the correction for the partial plan termination, and additional refunds are due to the HCEs.
Should the compliance testing for 2018 be re-run as a result of the corrective actions taken for the partial plan termination?
Thanks!