Coverage Testing Frozen Plan

[Guest mcfeldman]

Coverage testing for a DB plan frozen to new entrants - the plan was frozen to new entrants several years ago. It is continuing accruals for those who were in the plan at the time. Two questions: first, can those who are not age 21 with 1 year of service be excluded (even though the plan was soft frozen several years ago)? If they cannot be excluded, can they be treated as "otherwise excludable" and tested separately? Second, the employer has many workers who work less than 1000 hours. Based on a positive answer to the first question, can they be excluded with less than 1000 hours in the current year? Two most recent years? How many years back would I have to go? Thanks.