justatester Posted June 10, 2019 Posted June 10, 2019 I have 2 plans that are part of the same controlled group. Plan A: No age/service, daily entry Plan B: 21/1 YOS/Semi Entry When determining the groups for coverage, when doing plan A ratio, we count everyone since there is no age/service. When doing Plan B, do we only count those that have 1 YOS/21/semi for determining the benefiting group? I am trying to figure out who is excludable (for age/service) to those that are non-excludable not benefiting.
CuseFan Posted June 11, 2019 Posted June 11, 2019 Unless you carve out A's otherwise excludable early entries, I think you have to test coverage for A looking at everyone in A and B, and then for testing coverage in B you can exclude the under 21/1 employees in A and B. That is, you apply the eligibility criteria of the plan you are testing to the control group. If you have to aggregate, I think you use the most liberal eligibility requirements unless, again, you test OEs separately. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
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