entry date

[EBDI]

Plan year end is 3/31. Eligibility is age 20-1/2 and 1 YOS with quarterly entry dates. Eligibility changes to the plan year after the first year. Employee hires in 2009 with a DOB of 1/1/1995. He turned 20-1/2 on 7/1/2015. He has 2 YOS. Does he enter on the date he turns age 21 (7/1/2015) or at the start of the next plan year 4/1/2016?

[ETA Consulting LLC]

Does the plan say "following" or "coincident or next following". That provision should answer your question.

Good Luck!

[BG5150]

If not 7/1/15, then the next quarterly entry date of 10/1 I would think.

[My 2 cents]

I am familiar with plans that specify that a year of eligibility service runs from date of hire for the first year and changes to plan years thereafter, but I don't think that I have ever heard of a plan whose Entry Dates change like that. The plan either has quarterly entry dates or it has annual entry dates, but surely it doesn't have quarterly entry dates under some circumstances and annual entry dates otherwise.

The framework is to determine when the eligibility requirements are met and then enter on the first entry date on which the eligibility requirements have been met, with one set of rules establishing the date on which eligibility has been satisfied and another set of rules establishing when the entry dates occur. Entry should really be occur on the first entry date coincident with or next following, and the plan should say so. Entry should not be delayed if the person meets the eligibility requirements right on the entry date.

[EBDI]

The plan document does state coincident with or next following. My concern is that from 2009 to 2014, the employee did not work 1000 hours and was under age. In the plan years ending 3/31/15 and 3/31/16, he worked over 1000 hours. Age was met 7/1/15. Does he have to wait until the end of the 12 month period (the eligibility computation period) to enter the plan or does he enter as soon as he is 20-1/2? If he has to wait for the end of the eligibility computation period, the entry date would be the start of the next year which is 4/1/16. If he enters as soon as he turned 20-1/2, then he enters on 7/1/15. If I am reading the plan document correctly, he enters on 7/1/15. Would that be correct?

[david rigby]

Likely, his age at the time of working 1000 hours is not relevant. If he reaches a (possible) entry date and has met both of the age and service conditions at anytime during employment, then he should become a participant on that entry date, not the next one.

[EBDI]

David, thanks for the advice!

[My 2 cents]

1. He met the age requirement on the entry date 7/1/15.

2. Having worked 1,000 hours in the plan year 4/1/14 - 3/31/15, he met the service requirement no later than 3/31/15 (depending on how the plan is worded, it could have been prior to the last day of the plan year).

In any event, as of the entry date 7/1/15, he had met the age and service requirements and would have become a participant on that date.

If he were older and met the age requirement some time in 2013 or earlier, he would (depending on the exact language of the plan) probably not be able to enter until 4/1/15 because that would be the earliest quarterly entry date on which he would have met both the age and service requirements.

[Tom Poje]

possibly a better way of looking at it

you have 2 eligibilities.

1. service, first year is from DOH to anniversary and then switches to the plan year

2. age 20 1/2 this requirement doesn't switch to a plan year basis

he certainly had the service requirement but as you indicated he didn't meet the age requirement of 20 1/2 until 7/1/15

if that is one of the plan's entry dates that would be his date of entry

[EBDI]

Tom, that is a great explanation. Thanks to everyone for taking the time to help.