Accrual classes by name

[John Feldt ERPA CPC QPA]

At the ASPPA annual conference, Lorraine Dorsa mentioned that she tries to avoid using an employee's name when defining a rate class for benefit accrual (DB plans), to avoid the possibility of it creating a problem because of the 'similarly situated employee' issue. This approach was mentioned not just for NHCEs, but also for HCEs.

We have a few plans where the HCE accrual rate groups are defined by using the HCE's name, for example "Group A consists Captain John Smith, an owner-employee" and the document has a definition for owner-employee.

I think the potential problem exists any time one person ends up in a class by themselves, regardless of what language was used to get them into their own class.

Do you think this poses a significant issue or problem that would merit re-writing a few plans?