Gateway Testing

[justatester]

I have a MPP plan that is not passing the General Test. We want to cross test the plan. I know in order to cross test, you first must pass the gateway test. My question is who is included in the Gateway contributions? Is it only those who "benefit" (actually receive the contribution)? The MPP plan is part of a controlled group. It does not pass the ratio test on its own-but passes using Avg Benefits test. There are other ER contributions in the 401k plan. Do I need to consider those who do not receive the MPP contribution when performing the Gateway test?

Thanks for your help!

[ETA Consulting LLC]

You know you can perform the average benefits test without actually cross-testing. Will it pass on an allocation basis? Also, there are some exceptions to the gateway (i.e. broadly available) that you may want to explore should cross-testing be necessary.

Good Luck!

[justatester]

It does not pass on an allocation basis...I have 2 rate groups failing...It would potentially pass on an accural basis...So I am trying to figure out who is in the gateway test population.

[Lou S.]

My understand is the gateway applies to any employee who receives any (non-match) employer allocation. So participants who might have to be counted for other purposes such as 410(b) can be excluded from the gateway if they receive $0.00 allocation of employer contributions or reallocated forfeitures.