Separate Elgibility for Part-Timers

[Guest cxs]

I am doing coverage and ADP/ACP testing for a Plan that has 60 day eligibility for full time employees and 1 year (1,000 hrs) of service for part-timers. I reviewed previous posts and see that this is a fairly common Plan Design. I did the coverage test using the 60 day requirements and considered part-timers with more than 60 days but less than 1 year of service as not benefitting. If the Plan failed using this method is it OK to disaggregate into otherwise excludible testing? That would guarantee passing. Is any other testing necessary? Benefits Rights and Features? Sorry for my ignorance - it just seems too easy and I want to make sure I am not missing something.

[MWeddell]

Sounds like you understand the situation correctly. You may disaggregate those under age 21 or who have less than a year of service and test them separately.

There is no benefit, right, or feature testing required based on the facts you've told us about so far: within each disaggregated plan, all participants are treated the same.