Targeted QNEC question

[BG5150]

My document says I can do a targeted QNEC, wherein I can do a QNEC the greater of 5% or twice the "representative contribution rate."

That rate is defined as the lowest rate of the group that consists of half the NHCE's still employed at the end of the year.

I have 21 of those NHCE's. When I rank them by ADR, my 10th participant has 2.60, and the eleventh has 2.30. So, is half my population 10 or 11 participants? If its the former, I can get a QNEC of up to 5.2% to select participants; if the latter I can use 5%.

Your thoughts are appreciated.

[Tom Poje]

the regs say you look at a group that consists of 'half the eligible NHCEs'

I would hold that 10 is less than half of 21 and would fail to meet the requirements, so I would always round up

[Mike Preston]

Does the 0.002 multiplier really help you all that much?