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After the plan year has ended we, the TPA, begin compliance work and learn that Employee A was not given the opportunity to defer. Under EPCRS, we have calculated the missed deferral opportunity and missed matching for the employee. Client will be making a QNEC contribution to the plan in the amount of the missed deferral. Client will be making a matching contribution to the plan.

Plan uses prior year testing. My question is: do I run the ADP Test with the QNEC included to determine the level of deferrals allowed for the HCEs for the next plan year? Or is the employee in the test with a 0% deferral or not in the test at all?

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