Abpt

[Guest greggi39]

term employee with less than 500 hours but has deferred. he/she should be included in ABPT even though excluded from general test?

Quantech users: is software doing correctly?

thanks

[Tom Poje]

since there is no hours requirement more deferrals, they should be on the average ben % test. (stopping short of statutory exclusion rule if you had immediate eligibility or something like that)

It is optional whether you want to include these people in the rate group test. for instance, if some were HCEs it would only help to include them. (it is an all or nothing deal, you can't cherry pick, but you can change year to year)

last I check the system was working, but we just switched from 6 to 7.3 so I can't say for sure.

[Guest DFerrare]

I believe they would be in the ABPT even if they had not deferred, but were eligible to do so, since they would still be benefiting under the (k) component plan.

David

[Guest Tbrown]

We just went through this at length earlier this week because of the number of plans we have that have immediate eligibility for 401(k) and waiting periods for profit sharing. We were trying to do solving in the Relius proposal system for minimums for the NHCE's. After much research and also discussing it on the phone with Sal Tripodi, we came to the conclusion that you must include those employees who terminated but worked less than 501 hours in the average benefits test because they were benefitting under the 401(k). Those employees who worked less than the statutory requirements (otherwise excludable employees) could be disaggregated from the average benefits test but those terminees could not be. The 2002 Erisa Outline Book discusses it at length - pages 8.48 - 8.54 and 9.22 - 9.23. The Relius Proposal system doesn't handle it very well. You have to leave out those people who are otherwise excludable or the system picks them up. We are on Relius 8.0 for administration and so far, so good. It appears to handle it properly but I haven't been all the way through the test yet.

Tim