excluded compensation

[Earl]

I have started working on a 403b plan that has a compensation exclusion of "coach's compensation".  Provision does not specify that it applies only to ER contributions.  Some people are only coaches so they have plan compensation of $0 effectively excluding them from the salary deferral part of the plan (it seems to me.)

Does this situation create a problem with the universal availability requirement for the 403b benefit?

Thank you

[PensionPro]

yes, you may have a problem with effective opportunity under the universal availability rules:

https://www.plansponsor.com/blines-ask-the-experts-universal-availability-and-excluding-compensation/