Anticutback issue - change of timing of distribution

[Guest Star Seeker]

I'm in the process of preparing restated prototype document. Existing Money Purchase adoption agreement allows employer to elect a special timing rule for distributions on disability after separation from service. Plan allows for distribution of account exceeding $5k in the first plan year after separation for service. Special rule: distribution as soon as administratively possible after separation from service on account of disability.

New prototype Adoption agreement eliminated special disability distribution timing employer election. Plan language states that disability distribution is same as regular separation from service distribution. Is there an anticutback issue by eliminating the "as soon as administratively possible" exception?