Mid year change from a safe harbor QNEC to a safe harbor match

[AJ North]

Hi.  We have a plan that currently is a safe harbor 401(k) using a QNEC.  The plan now wants to change mid year to a safe harbor using a match.  I do not believe this is possible, since it reduces the amount of the required QNEC.  Notice 2016-16 indicates that changing types of safe harbor plans mid-year is prohibited and uses the example going from a tradition 401(k) to a QACA 401(k).  Most literature out there cites this as the only prohibition, but the IRS Notice indicates that this is an example, which would seem to indicate that there are other prohibited changes.   Is there anyone out there that has dealt with this question?  Thank you.

[Lou S.]

Not one of the allowable changes.

Can switch to match next plan year, stuck with the NEC this year unless you did 'maybe NEC' in which case the choice is NEC and SH or no NEC and no SH but you can't switch to safe harbor match mid year.