Participant or not

Calendar Year Plan

Effective 07/01/2022, the hours requirement for eligibility was changed from 1,000 hours to 800 hours in a 12 consecutive month period.

Employee was credited with more than 800 hours in the 2021 Plan Year, but is under 800 hours for the 2022 Plan Year.

I would think she is not eligible - but software says differently.

Does your software back-calculate the total number of years each time you process the eligibility?  Or does it potentially just increment by one, on top of the prior year's calculated total?

If the participant was in between 800-1000, then the software may have kept her with 0 years of eligibility service as of 12/31/2021, and then not given her a year for 2022 either because of the <800.  

I don't think it's really a software question. 

Did the amendment change eligibility for only new hires? or existing employees too? 
Were other participants let in on 7/1/2022 because of the 800 hour rule? or were they held out until 2023 being forced to wait until they had 800 hours in 2022 or by July of 2023?
 

If the amendment said for new hires only, well then the first possible entry with the 800 hours would be July of 2023. 

if the amendment wasn't specific, I would err on the side of letting the participant in. 

Others employees with at least 800 hours of service entered on 07/01/2022. The Amendment applied to all employees going forward, effective as of 07/01/2022. with at least 800 hours of service in a 12 consecutive month period.

If they worked more than 800 hours in 2021 why weren't they let in as of 7/1/2022? 2022 hours wouldn't even have been available / known as of 7/1/2022. 

Unless the amendment said that the 800 hours only applies if over for 2022 and future years (which wouldn't make sense since you said others were let in 7/1/2022). 

Ultimately it's a decision of the Plan Administrator to interpret the terms of Plan and make a decision. That said unless the Amendment specifically states that the reduce hours requirement will only be applied prospectively to employees after the Amendment is signed then I would be inclined to interpret in favor of the participant that the 800 hours requirement would apply retroactively as of the adoption of the amendment.