Initial CB Document - "Amend" Formula?

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Working on starting up a CB plan for a doctor group. For whatever reason they want to start out with small contributions in year 1 and then increase starting in year 2. They know the specific amounts they want to do for each doctor in each year.

Is there any issue with setting up the document to say "effective 1-1-17, this is the pay credit," and then have a second paragraph that says "effective 1-1-18, this is the pay credit"? Assume that the 1-1-18 pay credit is intended to stay in place for awhile, and that we're all good as far as any testing or 415 issues go.

I don't think I've seen a plan document set up like this before, but I'm trying to figure out how it'd be any different than simply listing the initial 1-1-17 formula in the document and then doing an amendment. Does it make a difference to the IRS or for any other purpose? Is it recommended to do an amendment, but wait until 2018 to do it for whatever reason? I'm thinking there shouldn't be any problem setting up the document with both formulas, but want to make sure I'm not overlooking something.

[Effen]

Form over function, and YES the IRS will have a big problem with it if you do it in the original plan draft.  They must be separate amendments or the plan will fail the accrual rules.  

I tried exactly what you are expressing and the IRS played the dream crusher.  Just do an amendment.  I don't see any problem doing them both at the same time, but waiting until 2018 to increase the formula would be fine as well.

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Thanks, Effen. "Dream crusher." I like that.

[My 2 cents]

I think it comes down to the idea that cash balance plans usually have to rely on ERISA's 133% accrual rule and under that rule, the accrual in no future year can exceed the accrual in the current year  or any earlier future year (all expressed as periodic benefits payable as of NRA) by more than a third.

Unless your planned jumped-up benefit for 2018 is only slightly higher than the initial benefit for 2017, you are not going to be able to pass the 133% rule if both levels are in the plan document on the effective date.  As all 133% rule testing is done for the current and future years (with no looking back), wait until 2018 and amend the higher level in then.  You won't, in 2018, be comparing anything to the 2017 accrual, so you ought to be OK.