Early Entry

Hello, we have a plan where 3 NHCEs were brought into the plan early.  They met the age and service requirement, but were allowed to defer prior to their entry date.  I have done a corrective amendment in the past by naming the individual being brought in early.  I thought there may be a better way to write the amendment to bring in multiple employees.  Does anyone have a sample amendment I could use or any ideas?  Also, do you specify the Rev. Proc. or Regulation # in your corrective amendments?

Do they share a hire date or are they the only hires within a specific range?  Naming the ppts is usually not recommended because it doesn't pass the definitely determinable and employer discretionary conditions.

If they share a common hire date, that might make it look better (and/or make someone feel better), but I see no problem with letting in NHCEs early and naming them by name. I don't understand how it could not be definitely determinable or be discriminatory.

It's more an issue when trying to pass coverage when using the average benefits test rather than ratio percentage test.