Datair Windows - Coverge Testing

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We are performing a coverage test using Datair Windows.

The plan we are testing has immediate eligibility for deferrals and 1000 hours in 12 months with semi-annual entry dates for the match.

The coverage test for the match contribution is pulling in all participants.

Datair is stating the test is correct because if the plan prescribes two or more different sets of minimum age and service eligibility requirements (for different sources), the excludable employees are only those who fail to satisfy all sets of age and service requirement (i.e., the lowest of the eligibility requirements must be used for all sources).

Am I missing something is this correct? I thought the sources could be disaggregated and tested separately using the eligibility requirement for the source?

[Tom Poje]

it is not a matter of "sources could be disaggregated"

1.410(b)-7© requires mandatory disaggregation, and quite clearly states the sources are treated as 'separate' plans.

while 1.410(b)-6(b)(1) certainly says that you use the minimum age and service,

however the paragraph before that 1.410(b)-6(a)(2) clearly states that this rule is applied 'soley' in reference to that 'plan'

However, the concluding statement adds 'In determining if a plan satisfies the average benefit percentage test ...then all plans in the tesing group are treated as a single plan'.

so, if, when referring to coverage, you are talking about the avg benefits % test, then it is true you would look at the min age and svc conditions. if you are talking about the ratio % test, then you look at the 'plan' or 'source' conditions.