Early Retirement Window Non-Discrimination Testing

[ubermax]

Want to General Test a window that provides 3 years added to age and service for those eligible for the window and not receiving Minimum Distributions but only a flat $10,000 for a couple of non-highs who are eligible for the window and receiving Minimum Distributions.

Have a couple of questions :

(1) Are the accrual rates and corresponding rate groups to be tested created by looking at the entire plan's participants or just those eligible for the window ?

(2) If testing on a benefits basis would you simply convert the $10,000 amounts to an annuity at current age - both participants are older than the testing age of 65- and then for say the annual method would the change in accrued benefit simply be the converted benefit plus the otherwise accrued minus the beginning of year accrued ?

For those eligibles not getting the $10,000 and again using the annual method I'm assuming the accrual rates would be determined by taking the accrued benefit reflective of the 3/3 and subtracting the beginning of period accrued which naturally doesn't reflect any enhancement ?