Rehire with different eligibility by source

[AlbanyConsultant]

This has to be relatively common, but I can't find anything that is clear on the topic (which probably means there is no clear answer)...

Calendar year plan has dual eligibility:

1. one-month eligibility for deferrals, entry on the 1st of the month coincident or next following

2. one YOS (1,000 hours) for safe harbor and profit sharing, entry on 1/1 & 7/1, and uses DOP compensation

The plan switches to calendar year eligibility periods if the YOS is not satisified in the initial one.

Dan was hired on 4/1/09 and left in 2011. He had never completed a YOS while employed (generally working about 100 hours per year), so never became eligible for safe harbor or profit sharing.

Dan is rehired in January 22, 2013, and works more than 1,000 hours in 2013. For deferrals, he has to be eligible right away (there's no "hold out" rule in the document). For the employer contributions, is he treated as a new employee and therefore becomes eligible on 7/1/14? Or because he's already a "participant", we just look at the calendar year and since he completes a YOS in 2013, he is eligible for those sources on 1/1/14?

Thanks...