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Posted

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. 

Posted

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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