Definition of 414(s) comp in a 401(k) plan with different eligibility requirements

A 401(k) Plan defines compensation as participating compensation based on the entry date of the participant.  When there are multiple eligibility periods and entry dates for the various contribution types, (deferrals, Safe Harbor Non Elective and Non Safe Harbor Non Elective), for purposes of the Gateway test, which participating compensation is used for 414(s)?  Thanks!

Does the document spell out what to use?

If the document gives you the leeway to use any 414s compensation, then sure, you MAY limit 414s to only periods of participation.  (You don't have to, but you have to be uniform for all employees.)

If you have separate participation comps (and a hearty "Blam!" to anyone who's forced that upon you) then I suppose you'd use the participation comp relevant to exactly what you're testing for.  If you're testing the gateway then you're measuring nonelective contributions by the employer, so use the participation date applicable to getting nonelective contributions under the plan.

44 minutes ago, Bri said:

If you're testing the gateway then you're measuring nonelective contributions by the employer, so use the participation date applicable to getting nonelective contributions under the plan.

Exactly. Each disaggregated component is a "plan" for coverage and nondiscrimination testing. 

On 3/3/2023 at 12:08 PM, Bri said:

...

If you have separate participation comps (and a hearty "Blam!" to anyone who's forced that upon you) then I suppose you'd use the participation comp relevant to exactly what you're testing for...

at my last employer we had three different participation comps because we had deferral employer match at 6 months, then a PS at 2 years and a different PS calc at 5 years. It was a pain and I had to manually calculate them each year because ADP couldn't calc YTD because of the entry (first of the month AFTER).... In my last few months there, I finally got ADP's system to be able to start the PS contribution correctly without having to input it in the specific payroll..... But yes, it was a large PITA!