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Never ran 2008 adp testing


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Guest Bosco108
Posted

Plan sponsor finally submitted "clean" data for 2008 adp testing. My assumption is that the adp test must be run without the use of testing the otherwise excludable employees separately.

I know that the otherwise excludable employees can be tested separately but can this testing method be applied after the 12 month correction period?

Posted

Step 1: Run the ADP test without OE's. If the testing passes you are fine. There is no requirement to RUN and ADP test. The requirement is to PASS the ADP test. If the test is passed, the fact that you didn't run it before 12/31/09 is moot.

Step 2: If you don't pass the test, now your correct, OE's cannot be included. You need to correct under EPCRS which involves making QNEC's. There's a couple of options available.

Austin Powers, CPA, QPA, ERPA

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