Cushion amount

[Guest skc]

Under PPA maximum deductible amount includes a "cushion" amount if the plan is "at-risk". There is special rule in determining the cushion amount if a plan has 100 or fewer participants. But under the definition of "at-risk" plan doesn't a plan have to have 500 or more participants. So how could a Plan be "at-risk" with 100 or fewer participants and have the cushion amount at all?