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Posted

If an eligible NHCE in a non-top heavy plan receives a 0% allocation for the year (the participant is not excluded, just receives 0%), is that person still included in the Gateway Minimum testing, which would therefore cause plan to fail test?

We use Datair, and when I give such a person 0%, the Gateway test still passes because the lowest allocation (to anyone receiving $) is 5%.

Posted

$0 is fine as long as you pass testing with the individual receiving $0.

Once the participant receives any employer allocation, say $1, then they now need to receive the gate-way. Strange but true.

Posted

If it is a pure DC plan then Datair has it right, as I would expect.

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