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Have a plan that did not auto enroll a few employees going back 3 years.  Am I crazy or is EPCRS silent on how to determine ADP in the case where the plan is tested separately for otherwise excludables?  Do I run one single test?  I guess that is the answer, but I can't find anything. Even the EOB seems to ignore this obviouis question...

Austin Powers, CPA, QPA, ERPA

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