Dual Eligibility

[justatester]

A plan has immediate eligibility for full time employees. Part Time Employees must work 1000 hours to be eligible for the plan. When running the coverage test, how do I count the part time employees. Non-excludable, not benefiting since none of them worked 1000 hours? Or are they excluded since they did not meet 1000 hours? Would it raise a BRF issue since the "right" to defer is delayed for this group/class of employees?

Any help would be appreciated!

[austin3515]

In general, no. You can have different eligiblity for different groups of people, and you are complying with 410(a), which governs eligiblity.

But I suppose if you had two employees in a startup, 1 an owner and one a part time employee scheduled for 25 hours a week, that could be a problem.