Running a ADP/ACP Test beyond 12 Months

[justatester]

The 2007 ADP/ACP test needed to be redone. The original tst did not include some pretax and matching contributions. The plan uses the prior year testing method. For the 2007 test, I know I use the 2006 averages. Can I use the disaggregated numbers? In other words, my 2006 test had two group the "otherwise excludable" and all others. Or do I need to revise my numbers to have one subgroup?

[BG5150]

I believe you can, but if you fail, you must make a 1-to-1 QNEC for the amount of the refunds. EPCRS says you cannot break the plan into component parts, so you must test everyone together, and, then base the QNEC off those results.