Client with more than 1 union plan ADP testing

[Guest anne1]

I have a client with numerous plans. 3 of them cover ONLY nonunion employees. Each plan covers a different union organization.

I know that when a single plan covers more than 1 union group, the employer has the option of ADP testing each union group separately or combining them in any way they choose.

Since this company has 3 separate plans, can I apply that same logic here? The company would like to run 1 ADP test for all 3 of the union plans. I know that normally you can't combine for ADP testing unless you are also combining for 410(b) but union are excluded from coverage anyway so that doesn't seem to be an issue. My concern, though, is that the employer would be combining the 3 union plans but keeping their other plans separate for testing purposes. Is this OK?