eligibility upon rehire

We have client that sponsors both a cash balance and 401(k) safe harbor.  A participant terminated in 2019 and was paid from both plans in 2020 and receive distributions of the entire account(s).

She has subsequently returned 6/17/2022.  Since less than 5 years, she enters both plans on her date of rehire.  She was FT when she quit, returned PT.  I seem to remember "once a participant, always a participant" so it is irrelevant she is now PT and must receive the safe harbor based on W-2.

Cash balance accrual is 1,000 hours.  Even though she may not have worked the 1,000 hrs, the question is, does she re-enter the cash balance plan and is entitled to receive the "hypothetical allocation"?

of course, the client tells me yesterday they will not be filing an extension and needs the contiubtio numbers today! (What else is new.)

Based on the information presented I think she would enter the CB plan but would not accrue any benefits since hours <1,000 required for accrual.  Which might require the 7.5% gateway for her as a side comment.

I generally agree on her entering the plans immediately upon rehire. However I do have a coupe of complicated rehire situations so I am also trying to do a refresher on BIS/rehires rules - can anyone point a good summary?

Hi, I think we've met.  I do have a couple of summaries, but do not believe they fully answered my questions.  You can email me - steve@thepensionmaven.com