"manage" census with young part-timers?

[Guest rickw]

I have heard the suggestion to employ young part-timers (like high school interns, kid's of other employees, etc.) to make cross-tested plan work where owner is, say, in their 30s and regular employees are same age or older.

Would something as transparent as this work, especially since the young kids would rarely be around more than a year and would never get vested. Would this fail the "discrimination in operation" kind of smell test, even though they provide a legitimate business service to the company?

Thanks!

[Blinky the 3-eyed Fish]

I don't see a problem with it. Of course to make this type of plan design work you need to have very lax eligibility and accrual requirements and will have many people in the plan you otherwise wouldn't have had.

[Guest rickw]

I realize that the ramifications of a lot of unintended part-timers would have to be considered on a case by case basis. Of course, if they are truly part-timers under 1,000 hours, they would never get vested even though they got a contribution, right?

Thanks!

[Blinky the 3-eyed Fish]

As The Fonz would say, "Correct amundo".