2 year employer match

[Lori H]

a high school has immediate entry on deferrals, but a 2 year waiting period for the employer match. their new doc states that for matching purposes, the match has two entry dates the earlier of the first day of the plan year (June 1) meeting 2 year requirement or first day of the 7th month(dec 1). However, they have not been administering the plan as such. They assess eligibility at the first day of the plan year (June 1) and if a employee lets say started working in August of 2007, they qualify for the two year requirement as of June 1, 2009 or appx 1.8 years. Something under the "3/5ths rule". Since they are a school and a lot of their employees being in August.

Aside from the fact their document is not in line with how they are administering the plan, is this 3/5ths rule ok?