"easy" eligibility question crossing the plan year

[AlbanyConsultant]

Calendar year plan, employee is hired during the last week of 2019.  However, the first paycheck they receive isn't until the first week of 2020 (and counts on the 2020 W-2).  Does the universal availability clause require that the participant be counted as a participant in 2019, even though there is no official 2019 compensation?  And this plan has an ACP Test - I would say that the participant had no opportunity to receive a match and therefore can't be counted in the 2019 ACP Test... but I would have to include them in a coverage test.  I don't really have a basis for that (yet), but it seems ridiculous to include someone in a test that they had no opportunity to take advantage of (hmm, so then why include them in 410(b) testing?).  Any sage advice?  Thanks.

[Bill Presson]

Assume you're talking about a 403(b) plan?

I wouldn't show them as eligible for 2019 if they have no ability to defer.

[AlbanyConsultant]

Yes, in a 403b plan.  Thanks.