Highly Compensated Employees

[mjf624]

If the Plan Document uses base pay, what is the determination for a Highly Compensated employee? Base pay or Total pay?

[Tom Poje]

you are probably indicating that base pay is used for allocation purposes. (e.g. exclude bonus or commission, etc) that has nothing to do with HCE determination which should be total pay.

that would be no different than using comp from date of entry for allocation purposes, you would still use total pay to determine if the person was an HCE