Short Plan Year - CRoss-Testing

[austin3515]

What limits need to be prorated for a short plan year? I know the SSWB, 415, and Comp, but how about covered comp? Anything else?

[Tom Poje]

as I recall:

covered comp yes (but not the % (e.g. 5.7%)

hours for vesting are always based on a 12 month period (so in effect, in an existing plan, some hours get counted twice)

HCE determination is also based on a 12 month period.

[austin3515]

Thanks Tom! [Mine is actually a plan termination, so the two you mentioned that I hadn't wouldn't apply]

So for covered comp, it's the same calculation to determine covered comp, you just multiply it by 8/12 (my plan year runs through August). Is that right?

[Tom Poje]

1.401(l)-2(d)(5) says to prorate the integration level