Average Benefits Test for Coverage

[Blinky the 3-eyed Fish]

In running the average benefits test to determine if the plan passes coverage, I know there are three options: use the current year benefit percentage, the current and prior year's average of the benefit percentages or the current and prior 2 years' average of the benefit percentages.

My question is in determining the last two options, do you use the participants in each year or only the participants in the current year. I would suspect the later since coverage is a plan year thing.

[AndyH]

I can't say with authority, and I know of nothing in print on this issue, but since there have been no responses I thought I'd express the opinion that it would be the group currently required to be included only, which is what you were leaning toward.