ADP/ACP - Prior Year Percent Method - Plan Year Change

[fiona1]

Here is the situation. 10/1 plan year changed to a 1/1 plan year effective 1/1/04.

ADP/ACP test was done 10/1/02 to 9/30/03.

Short Year ADP/ACP was done 10/1/03 to 12/31/03.

Now doing the 1/1/04 to 12/31/04 ADP/ACP nondiscrimination test and the Prior Year Testing method is used.

What are the PY Method rules in this situation? Do we use the short plan year NHCE average?

Thanks for any help!!

[Guest Midas]

Yes. You would use the short year NHCE %s.