Service Spanning rules and entry date

Plan specs:  age 21, 2 mos service, monthly entry.

Participant:

DOH  3/7/21

DOT  4/29/21 (not 2 month svc)

RH  10/5/21

When is entry date?  Rehire date or 11/1/21?

Slight change

DOH  3/7/21

DOT  5/17/21 (2 months but did not make entry date)

RH  10/5/21

When is entry date?  Rehire date or 11/1/21?

I thought that if they achieved the service but left before entry date and got rehired later (and after an otherwise entry date has past) then they are eligible immediately. (sencond example)

But if they didn't get the service requirement the first time and only by the spanning rules that get it, they they will enter the plan on the next entry date. (first example)

Document should lay that all out, especially if pre-approved, but you likely need to consult the basic plan document rather than adoption agreement. That said, I agree with your assessment - recently had similar situations that we resolved in that manner (we use FTW docs).

We use Relius documents (PPD version). In one of their document seminars, they went through a similar situation and described months of service as simply a passage of time. So, if an employee was employed on the entry date, they entered on that date regardless of how many times they may have been terminated and rehired. If that is the case, I think both of your examples would result in an entry date on the rehire date. (Of course, other documents could be worded differently.)

If they had originally remained employed until the next available entry date and had meet eligibilty, then they are immediately eligible upon rehire, second example.  If as of the next available entry date after termination they would not have been eligible, then they need to complete the eligibility requirement as of the next entry date after rehire first example.  Double check that contiguous service is not required.