ADP test

[Belgarath]

So, employees who have otherwise satisfied eligibility requirements of 1 year/1,000 hours are in an excluded class. While they must be included for coverage testing, must you include them for ADP testing? 1.401(k)-6 isn't specific on this issue. I can see arguments for either side.

[Tom Poje]

1.401(k)-2(a) refers to 'eligible employees' and 1.401(k)-(6) defines eligibile employee as someone who directly or indirectly is eligible to defer.

so if you are excluded from the plan, but hae met the eligibility require,emt you get tretaed as includable and not benefiting for coverage, and don't show up on the ADP test.

(A similar situation exists for the ACP test (including those who maight fail last day or hours requirement)

This is also true if you have more than one plan - if you chose to test coverage separetly then you wouldn't include the folks in the other plan in you ADP test.

[Belgarath]

Gracias. That's what I gave for an answer, but then I thought it might be prudent to see if I'm the only person on the plant who takes that interpretation!