QACA Safe Harbor Plan and Missed Deferral Opportunity

[MarZDoates]

I’m confused.  Plan is a safe harbor 401(k) using an automatic contribution arrangement to satisfy the 401(k) safe harbor requirements.  Plan sponsor failed to implement an employee’s affirmative election.  I’m reading EPCRS.  One part says that the plan sponsor has to make a QNEC.  

Another part says that sponsor does not have to make a QNEC if the failure was corrected within 9 ½ months after the end of the plan year.  Does this  “special safe harbor correction method” apply to traditional automatic contributions only?  Or does it apply to QACA arrangements.

[BG5150]

It applies to QACA.

Still have to make the match, though, if that is the SH contribution.