Coverage Testing in a control group

[cpc0506]

Employer owns 3 companies. Controlled group situation exists.

Each company has its own plan. Plan A, Plan B and Plan C.

Client does not want to aggregate all the plans and wishes to test each plan separately. I understand that if each plan passes coverage on its own, we can do separate ADP/ACP testing.

My question is:

Is this an all or nothing situation? EIther each plan passes coverage separately or they are combined as 1, coverage is run and then other compliance tests follow OR can you combine Plan A and B, and if this combined plan passes coverage and Plan C passes coverage, you can then run your compliance testing separately for Combined Plan A&B and Plan C?

I hope I am making some sense here.

[Tom Poje]

you can combine in an way shape or order you please. but what you combine for coverage must also combine for nondiscrim.

so you could have

ABC

A B C

AB C

AC B

A BC

one of the things to watch out for is the terminee < 500 hours rules, for one has to be a 'particpant' for that rule to apply.

so when testing A by itself, employees of B and C are includable and not benefiting for coverage, even if they quit with < 500 hours. But they would not appear on the ADP test