Benefits, Rights, Features

[justatester]

I think the answer is yes...but just want to double check.

I have a plan that have a 50% to 6% match with no hours or last day requirement. The plan has decided to make an additional discretionary match of 100% on 1%, but has an hours last day requirement. For coverage we are good since the first match everyone is eligible to receive. However, I believe the plan now will need a BRF test since not all employees are receiving the second match. Is this correct?

[MWeddell]

I generally agree.

If you perform the testing on a snapshot basis using the last day of the plan year as your snapshot date (increasing the passing thresholds by 10% consistent with Rev. Proc. 93-42), you might be able to avoid doing the extra BRF testing because you might have your entire eligible population getting the same match rate. It depends on your exact facts: is there both an hours and a last day requirement?