What is the Plan Entry Date when Immediate but requires 12 months and 500 hours

[Megandps]

Our client is wanting to change their eligibility requirements to Age 21, 12 months of service and 500 hours, with plan entry being immediate. Basically if the employee is at least 21 and has completed 500 hours within their first year of employment, they would enter the plan as of their 1 year anniversary date.

Where we are getting stuck is what if the employee does NOT meet the 500 hours within the anniversary year? We would be switching to evaulating the 12 month period then on a plan year basis. If the employee then completed 500 hours between the plan year of 1/1 and 12/31, does the entry date become 12/31 of the plan year the 500 hours was completed, or is it 1/1 of the following plan year? 

[Bri]

Sounds like it's a document language question - Read the definition of entry date.  If it says it's the date "coinciding with or next following" completion of the eligibility requirements, then completing the subsequent year of service on 12/31 means 12/31 becomes the employee's entry date.   If it only says entry occurs on the date following completion then it'd be the 1/1 afterwards.

The old "tie goes to the runner" argument, as I like to call it.

[CuseFan]

1 hour ago, Megandps said:

We would be switching to evaulating the 12 month period then on a plan year basis.

You could continue looking at hire date anniversaries for the subsequent eligibility computation period, there is no requirement to shift to the plan year.

[BG5150]

Talk to the authors of your plan document.  They should tell you how to do the amendment and when people will and won't come in.