Non-discrimination testing when plan offers different benefits to full

[Guest kredlin]

If an employer has a Section 125 plan which includes pre-tax health benefits, Sec. 105 medical savings account benefits, and sec. 129 benefits that is offered to full time employees and wishes to offer only pre-tax health benefits to part-time employees, would it make nondiscrimination testing easier if the employer creates a separate plan for the benefits offered to part-time employees instead of just amending their current plan?

[SLuskin]

No, you have to test for the DCAP plan on all the employees, even the part-timers. The test results don't change just because you put some of the employees in a different plan.