Corrective QNECs and ADP test

[Guest ghutson]

If a plan made corrective QNECs to eligible participants who were inadvertantly ommitted--assuming the QNEC was made during the same plan year as the ommission--can the QNEC amounts be included in the ADP test? I've searched the ERISA Outline Book, and haven't found anything.

[Tom Poje]

look in EPCRS, which is rev proc 2006-27

appendix A .05(f)

you can not correct for missing ees until after you correct adp failures