Missed opportunity in a EACA plan

[cpc0506]

Client thought employee Y was not eligible to participate in plan because they considered her a part-time employee.  Entry is immediate for deferrals (and 1 YOS for match with semi-annual entry dates) but Plan does have a part-time employee exclusion, but that exclusion no longer applies once an employee works 1000 hours in the computation period.

Employee Y was hired on 2/11/11 as a part-time employee.  At the end of the 2011 plan year, we learned that she had worked 1000 hours.  What would you consider her entry date into the plan?

Since the plan has an automatic 2% contribution rate, should we be calculating the missed deferral opportunity at 2% or do we rely on the ADP test results and use the average rate of the NHECs?

Please advise.

[BG5150]

EPCRS has the correction for missed deferral in an auto-enrollment plan, I think.