Leaving PEO, starting single ER plan, what happens to QACA?

I have a client leaving a PEO and establishing single ER plan. Within the PEO, they had QACA design and are leaving 11/1. Plan year end is 12/31.

Can they continue the QACA in the Single Plan even though it was not adopted until mid year? Thanks

Update to this, when leaving the PEO, the plan is being spun out so the new plan is a continuation of the plan so a QACA should be fine to continue as a single employer plan, is that accurate? Thanks