Leased Employee - When should she be including in coverage & non-discim testing?

[MarZDoates]

Corporation sponsors a 401(k) plan w/ fye 3/31. Eligibiity is age 21 and 1 yos w/ semi-annual entry dates.

They utilize the services of an individual through a temp agency beginning 6/25/13. This individual has worked more than 1500 hours to date. Assuming she is still performing services for the Corporation on 6/25/14, we determine that she is a leased employee.

The plan excludes leased employees from participation. Should she be included in coverage for the plan year ended 3/31/15?

If the plan does not exclude leased ees from participation, would she enter the plan on 10/1/14?

Thanks.

[Jim Chad]

FWIW I think yes and yes.

[MarZDoates]

Thank you.