leased employees vs. 6-month eligibility

[AlbanyConsultant]

When we got our 2015 census data for Client M, they mentioned that they have leased employees that started with them in late 2014 and are still employed. It seems that they meet the requirements of 414(n) at this point so they are considered "leased employees".

The plan has a six-month eligibility for 401(k). If we're supposed to count service back to the original date of hire, do we have a missed deferral opportunity? It seems like we shouldn't, since they weren't eligible as of that date. My thought is that we count them as eligible as soon as they meet the criteria to be counted as a leased employee.

Thoughts? Thanks.

[Belgarath]

I agree - eligible as of the date they officially become a "leased" employee.