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Posted

A 403(b) plan’s definition of a Year of Service (YOS) is 1,000 hours in Eligibility Computation Period, and it switches to the Plan Year after that.

 The Plan Entry Date is “Immediate”

 So, if during an Employee’s initial year, they don’t get 1,000 hours, it shifts to the Plan Year.

 And, then, if they do get 1,000 hours in that next Plan Year, when is the entry date?  They satisfy the YOS on 12/31 (it’s a calendar year plan).

 So, are they eligible on 12/31?  The plan has participation comp.  Do they have just one day of comp for the Employer contribution?  Or do they get a contribution for the payroll that includes 12/31. That is the next year?

 Or do they simply enter on 1/1?

 

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

Would need the actual document language, but I'm suspecting that the YOS is upon completion of 1000 hours, the computation period is merely a measuring window.

Posted

If there is no explicit language or example in the plan document, then the Plan Administrator needs to step up and provide an interpretation.  This can be one of those interpretations that says the entry date is 1/1 because the eligibility computation period was not completed until the stroke of midnight on December 31.  Another Plan Administrator may decide that the ECP ended at close of business on December 31 and says to use the compensation earned on that one day.  Or not.  Whatever the interpretation, document and communicate it.

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