IRC 410(b)(6)(c) and adp/acp testing

[Guest jae3207]

If a plan qualifies for transition relief from coverage under IRC 410(b)(6)©, can they test otherwise excludable employees for nondiscrimination purposes? In other words, if the plan does not formally run coverage testing on the otherwise excludable employees due to transition relief, can they disaggregate their adp/acp tests for those who meet the statutory minimum requirements and those who do not?