Seasonal Employees exclusion form Plan question ..... again.

[Hoard1]

Employer hires seasonal employees each year for a period of four to six months April to September. Many of these employees are over age 21 and work over 1000 hour in the season.

If these employees are rehired in the next season, when must they participate in the plan( date of rehire or next entry date July 1)? From prior posts on the BB I see that exclusion of these employees is difficult because of an IRS Field Dirrective and 410(B) coverage rules.

Has anyone come up with any approaches to exclude these employees other than:

1) Write HEC's out of Plan and establish non-qualified program for them.

2) 410(B) carve out to exclude enough HEC's to pass coverage.

[Hoard1]

Also, does anyone have a copy of the IRS Field Directive that talks about seasonal emloyees? I lokked for it through my usal sources and it appears that it is not yet posted.

Thanks