Minimum Participation Rules for Non-Electing church plans.

[Guest gaaberggillespie]

Under IRS Notice 98-39 and 2001-9, non-electing church plans are now subject to non-discrimination testing. What employees must first be considered for purposes of the testing,i.e. same as for 401(a) plans for purposes of minimum service and hours?

Example: church plan contributes 7% of pay, but only to employees who work full time (30 or more hours per week) and who have been employed 3 years as a full time employee.

Are churches subject to a maximum waiting period of 1 year (2 years with 100% vesting) now same as for other 401(a) plans?

Is a church still exempt from having a written plan if the employer monies are contributed to a 403(B)(7) account along with the employee's TSA salary reductions?