How to test controlled group with 2 different plans?

Hi

I was just asked to do a 2020 run for controlled group situation - employers, 2 plans (because the payroll company will not do it - shall not be named) as a favor. Must do it prior to 10/15. No good deed goes unpunished i.e. I just checked all the provisions and unpleasantly surprised.

If any of the gurus have some suggestions on testing for top heavy and also coverage, would appreciate it.

Plan B is not top heavy but not sure about plan A yet as I am waiting for assets. I also do not know if combined plans will be top heavy - to be determined.

Provisions of each plan are as follow:

Plan A (Company A's plan) has 3% non-elective safe harbor, 401k deferral and profit sharing (1000 hours and must be employed at EOY). No compensation exclusions. For all provisions, entry date is the month following age 21/1 year service.

Plan B (Company B's plan) has enhanced match (100% of elective not in excess of 6% of compensation, 401k deferral and profit sharing (must be employed at EOY - no hour requirement). Only for match, compensation is from date of entry (No way for me get this unless payroll company will provide it). For all provisions, date of entry is the next payroll period (Plan is run by a payroll company so they can do this, I guess) upon satisfaction of age 18/1 year of service.

They want to have PS allocation in Plan A and none in Plan B. PS allocation for Plan A is group based i.e. needs to be tested.

I need to combine both for top heavy even if each plan passes 410b and 401a4 on its own (they do).

Since each plan has different safe harbor assumptions, separately top heavy for each plan is not an issue, one is 3% non-elective and the other one is enhanced match.

Do I need to test them all together for coverage and non-discrimination? What would the answer be if

• If Plan A is top heavy, Plan B is not and combined not top heavy
• Neither plan is top heavy and combined not top heavy
• If Plan A is top heavy, Plan B is not and combined they are top heavy

What am I not asking properly? I never had to test two DC plans like this.

Any words of wisdom is appreciated.

Thanks