Leased Employees and HCE determination

[Guest andmik]

Employer A hires from the Leasing Company all the leased employees who have been working for Employer A's subsidiary. Effective 1/1/2001 these former Leased Employees are part of Employer A's payroll.

I am required to include the service with the Leasing Company for eligibility and vesting purposes in Employer A's Plan. For ADP/ACP purposes, am I obligated to use the 2000 salaries with the Leasing Company as the benchmark in determining any HCEs for 2001 from this group of Leased Employees?

Thanks in advance for any insight. Andmik