Two Eligibilities and Coverage Testing

[TPA Bob]

Realize this not a cross tested question but seems to be the best place to post.

We have been approached by a new Company that was spun off from a larger Company - new ownership and no relationship to prior Company.

They want two classes of employees with different eligibilities. For "field employees" they want six months of service with monthly entry dates. For all other employees they want immediate eligibility.

For coverage I assume that I have to test each eligibility requirement separately for coverage. But the Plan Sponsor is telling me that since both eligibility definitions would cover otherwise excludible employees all of the employees are aggregated for coverage. I am thinking that each class of employees need to be tested. Any thoughts would be greatly appreciated.

[Tom Poje]

let's say I have 1 employer with 2 companies, company A and Company B

by chance, company A consists of all field employees and Company B consists of all other employees.

each has it's own plan.

How would you test?

(There is certainly nothing to prevent you from setting the plan up that way - and testing by aggregating the plans or testing each plan separately, or for that matter, having one plan and breaking it up into component plans)

[TPA Bob]

I would have in the ratio % all non excludable employees in the denominator and in the numerator the covered employees of the particular company.